before the public utilities commission of … the public utilities commission of the ... law judge...

LIMS-314-8357

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Pacific Gas and Electric Company for Approval of 2013-2014 Statewide Marketing, Education and Outreach Program and Budget (U39M).

Application 12-08-007 (Filed August 3, 2012)

And Related Matters.

A.12-08-008 A.12-08-009 A.12-08-010

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE ROSCOW’S ORAL REQUEST AT THE

PREHEARING CONFERENCE

JANET S. COMBS ANDREA L. TOZER

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-7740 E-mail: [email protected]

Dated: July 31, 2015

1


STATE OF CALIFORNIA




A.12-08-008 A.12-08-009 A.12-08-010

SOUTHERN CALIFORNIA EDISON COMPANY'S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE ROSCOW’S ORAL REQUEST AT THE

PREHEARING CONFERENCE

In compliance with Administrative Law Judge (ALJ) Roscow’s oral request at the April

16, 2015, Prehearing Conference (PHC) in the above-captioned matter, and pursuant to the Rules

of Practice and Procedure of the California Public Utilities Commission (Commission or CPUC),

Southern California Edison Company (SCE) hereby responds to ALJ Roscow’s request for

clarification of SCE’s PHC Statement and any allegation of a Rule 1.1 violation.

During the PHC, ALJ Roscow asked SCE to determine whether the statement in its PHC

Statement that “all stakeholders agreed that paid media was no longer needed”1 is reflected in the

Flex Alert Transfer Proposal filed on April 1, 2014, (Transfer Proposal) and respond in writing.

In the PHC Statement, SCE stated that: Specifically, SCE recommends that the Commission continue to consider the Transfer Proposal filed in 2014, which relied on several program and impact evaluation reports to justify discontinuation of paid media. Although the IOUs and the CAISO did not agree about potential administration and funding sources, all stakeholders agreed that paid media was no longer needed. Thus, SCE

1 SCE’s PHC Statement on Phases One and Two for Statewide Marketing, Education, and Outreach, filed April 6, 2015, (PHC Statement), p. 5.

2

requests that the Commission allow the IOUs to continue coordination with CAISO to reach agreement on administration and funding of non-paid media activities.

SCE has reviewed the Transfer Proposal again, and acknowledges that the proposal does

not explicitly state that CAISO supported the recommendation to discontinue IOU funding for

paid media for the Flex Alert program. In SCE’s view, this omission resulted from last-minute

changes to the Transfer Proposal when the IOUs and CAISO could not agree on a funding source

for administrative costs associated with the transfer of the Flex Alert trademark, managing the

Flex Alert Network, and coordination of websites maintaining Flex Alert content. However, at

no time did CAISO and the IOUs disagree that paid media should be discontinued.

On March 14, 2014, just two weeks prior to the Transfer Proposal filing, SCE received a

revised draft of the Transfer Proposal from CAISO that demonstrated CAISO’s concern about

funding administrative costs and agreement to discontinue funding paid media. The draft

Conclusion stated:

The costs for this approach for the Flex Alert program would be significantly less than the costs incurred for the previous years due to the lack of paid advertising, but may still be more than is appropriate to incorporate into CAISO operating costs without similarly appropriate cost allocations (i.e., based on cost-causation) to utilities…. Therefore, the Utilities and the CAISO recommend that reasonable costs for the administration and implementation of the continuing Flex Alert program (i.e., not including paid advertisements or activities associated with securing and managing paid advertisements) remain within the oversight of the Commission.2

On March 27, 2014, just five days prior to the filing, CAISO sent SCE a revised Transfer

Proposal that maintained the above content quoted above. However, CAISO inserted a new

section proposing that the IOUs would provide funding for CAISO to administer the remaining

unpaid media activities (i.e., website, trademark, and Flex Alert Network).3 The IOUs rejected

the proposal to fund a program that CAISO would administer. Without agreement on funding

administrative costs, SCE modified the document to remove from the Transfer Proposal any

2 Declaration of David P. Lowrey, attached as Appendix 1 (Lowrey Decl.) ¶ 3, pp. 1-2. 3 Lowrey Decl. ¶ 4, p. 2.

3

proposal regarding the source of administrative funding, and to separate the IOU

recommendations and CAISO recommendations. In this process, the recommendation to end

funding for paid media was not transferred into the CAISO recommendation section. That was

an editing error, however, that was not intended to reflect any change in CAISO’s or the IOUs’

positions on discontinuing funding for paid media.4

The IOUs and CAISO could not ultimately agree on the administrative funding aspect of

the Transfer Proposal, but no party expressed a change in the unanimously held position to

discontinue funding for paid Flex Alert media. Although it was not clearly stated in the Transfer

Proposal, at the time the Transfer Proposal was filed CAISO agreed with the recommendation to

end paid media, and that remains CAISO’s position today. SCE’s PHC Statement accurately

reflected the positions of the stakeholders at the time of the Transfer Proposal and today.

Respectfully submitted, JANET S. COMBS ANDREA L. TOZER

/s/ Andrea L. Tozer By: Andrea L. Tozer

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-6713 Facsimile: (626) 302-7740 E-mail: [email protected]

July 31, 2015

4 Lowrey Decl. ¶ 8, p. 2.

Appendix 1

LIMS-314-8365 1


STATE OF CALIFORNIA




A.12-08-008 A.12-08-009 A.12-08-010

DECLARATION OF DAVID P. LOWREY

I, David P. Lowrey, declare:

1. I am employed by Southern California Edison Company (SCE) as a Senior Project

Manager in the Regulatory Affairs organization.

2. SCE’s statement that “all stakeholders agreed that paid media was no longer needed”1

was not explicitly stated in the Transfer Proposal, however it accurately reflected the

position of the IOUs and California Independent System Operator (CAISO) at the

time of the Transfer Proposal and the PHC Statement filings.

3. On March 14, 2014, SCE received an email from Gregory Van Pelt of CAISO

providing a revised draft of the Transfer Proposal.2 The March 14, 2014 version of

the Transfer Proposal stated:

1 SCE’s PHC Statement on Phases One and Two for Statewide Marketing, Education, and Outreach, filed April 6, 2015, (PHC Statement), p. 5.

2 Attached as Exhibit 1, draft Transfer Proposal, p. 12.

LIMS-314-8365 2

The costs for this approach for the Flex Alert program would be significantly less than the costs incurred for the previous years due to the lack of paid advertising, but may still be more than is appropriate to incorporate into CAISO operating costs without similarly appropriate cost allocations (i.e., based on cost-causation) to utilities….

Therefore, the Utilities and the CAISO recommend that reasonable costs for the administration and implementation of the continuing Flex Alert program (i.e., not including paid advertisements or activities associated with securing and managing paid advertisements) remain within the oversight of the Commission.

4. On March 27, 2014, just five days prior to the filing, Mr. Van Pelt of the CAISO sent

SCE a revised Transfer Proposal (Version 6.1) that maintained the content quoted in ¶

3 above. However, CAISO inserted a new section proposing that the IOUs would

fund the remaining unpaid media activities and contract with CAISO to administer

those activities (i.e., website, trademark, and Flex Alert Network).3

5. Because the IOUs and CAISO could not agree on a funding proposal for

administrative costs, SCE modified the document to remove from the Transfer

Proposal any proposal to fund the administrative costs. On March 28, 2014, SCE

circulated this draft (Version 12)4 to stakeholders for final edits and approval.

6. On March 31, 2014, a final draft was circulated to stakeholders which incorporated

edits received on Version 12.5

7. On April 1, 2014, CAISO stated it was “okay with this version” (e.g., Version 12).6

8. Without agreement on funding administrative costs, the IOUs and CAISO elected to

divide the Transfer Proposal into separate sections for CAISO recommendations and

IOU recommendations. In this process, the recommendation to end funding for paid

media was not transferred into the CAISO recommendation section. That was an

editing error, however, that was not intended to reflect any change in CAISO’s or the

IOUs’ positions on discontinuing funding for paid media.

3 Attached as Exhibit 2, revised Transfer Proposal (Version 6.1), pp. 9, 15. 4 Attached as Exhibit 3. 5 Attached as Exhibit 4. 6 Attached as Exhibit 5.

LIMS-314-8365 3

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Dated: July 31, 2015 By: /s/ David P. Lowrey

David P. Lowrey

Exhibit 1

1 Attachment

Roland,

Thank you for sending the revised proposal for review. I didn’t see reference to the many of the comments we made on Monday, March 10 and so I’ve included some suggested edits for your review and consideration.

I’ll be at the CPUC in San Francisco all day Monday and tied up in meetings Tuesday morning, but Tuesday afternoon may be available if you would like to discuss any thoughts or questions you may have about these suggested edits. Let me know if such a discussion would be helpful.

If you call and I’m not at my desk, please leave a message when the best time to call you back. Thank you.

Regards,

Gregory Van PeltOffice: 916-351-2190 Cell: 916-802-9133

California ISO250 Oucropping Way, Folsom, California, 95630

If you have received this electronic message in error, please notify the sender immediately. The foregoing e-mail communication (together with any attachments thereto) is intended for the designated recipient(s) only. Its terms are confidential and may be protected by the attorney/client, or other applicable, privilege. If you are not the intended recipient, you are hereby notified that any use, disclosure, copying, distribution (electronic or otherwise), or taking any action in reliance on the contents of this information is strictly prohibited.

From: Roland.Mollen@ sce.com [m ailto:Roland.Mollen@ sce.com ] Sent: Thursday, March 13, 2014 2:22 PMTo: GValdivieso@ Sem prautilities.com ; Van Pelt, Gregory; KxHm @ pge.com ; MCostello@ sem prautilities.com ; MEW r@ pge.com ; NxF9@ pge.com ; Greenlee, StevenCc: Brian.Kopec@ sce.com ; Dadras, Shada; Aim ee.W ong@ sce.com ; David.Lowrey@ sce.com

{In Archive} RE: For review by 3/20: Flex Alert Transfer ProposalVan Pelt, Gregory to:'[email protected]'03/14/2014 05:54 PMCc:"[email protected]", "[email protected]", "Dadras, Shada", "[email protected]", "[email protected]", "[email protected]", "[email protected]", "Greenlee, Steven", "[email protected]", "[email protected]"Hide Details From: "Van Pelt, Gregory" <[email protected]> Sort List...To: "'[email protected]'" <[email protected]>, Cc: "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "Dadras, Shada" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "Greenlee, Steven" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>Follow Up: Urgent Priority. Follow upArchive: This message is being viewed in an archive.

Flex Alert Transfer Proposal- ISO comments redline.docx

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6/12/2015file:///C:/Users/lowreyd/AppData/Local/Temp/notes0A94C5/~web8752.htm

Subject: For review by 3/20: Flex Alert Transfer Proposal

< EXTERNAL email. Evaluate before clicking. >

All,

Attached the revised Flex Alert Transfer Proposal, which includes edits based on our discussion this past Monday and from input I've received individually from some of you. Kind request to submit your comments (in tracked changes) and approval byThursday, 3/20.

I'll do a final true up on 3/21 and confirm IOU approval before starting the procedure to file and serve the proposal by 3/31.

Thanks in advance for all your input!

Roland MollenProject ManagerDSM Strategy & PolicySouthern California EdisonDesk: (626) 302 0855 PAX 20855Cell: (909) 471-0918

Follow SCE: SCE.com | LinkedIn | Twitter | YouTube

EMAIL DISCLAIMERPlease Note: The information contained in this message may be privileged and confidential, protected from disclosure, and/or intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, distribution, copying or other dissemination of this communication is strictly prohibited. If you received this communication in error, please immediately reply to the sender, delete the message and destroy all copies of it.

*********************************************************************************************The foregoing electronic message, together with any attachments thereto, is confidential and may be legally privileged against disclosure other than to the intended recipient. It is intended solely for the addressee(s) and access to the message by anyone else is unauthorized. If you are not the intended recipient of this electronic message, you are hereby notified that any dissemination, distribution, or any action taken or omitted to be taken in reliance on it is strictly prohibited and may be unlawful. If you have received this electronic message in error, please delete and immediately notify the sender of this error.*********************************************************************************************

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Flex Alert Transfer Proposal


Table of Contents

A. BACKGROUND ........................................................................................................ 1B. SUMMARY OF PARTIES’ POSITIONS ON FLEX ALERT PROGRAM .................................. 2

1. SDG&E Finds Need For an EM&V Study .......................................................................................... 22. SDG&E Proposed Transferring the Flex Alert Program to CAISO ................................................. 2

C. FLEX ALERT RESEARCH FINDINGS ........................................................................... 31. 2006-2007 Flex Your Power NOW! Evaluation Report .................................................................... 32. 2008 Flex Alert Campaign Evaluation Report ................................................................................... 33. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and

SDG&E’s Peak Time Rebate Programs ............................................................................................ 44. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program ...........................55. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program ............................................. 56. February 6, 2014 Flex Alert Event Media Report.............................................................................. 67. Overall Flex Alert Research Studies Conclusions ............................................................................ 7

D. FLEX ALERT PROGRAM COST/BENEFIT OVERVIEW ................................................... 8E. FLEX ALERT PROGRAM TRANSFER PROPOSAL ......................................................... 8

1. Flex Alert Responsibilities Should Be Transferred to CAISO .......................................................... 82. Discontinue SCE, PG&E, and SDG&E Funded Flex Alert Campaigns .......................................... 93. Utilities Should Integrate Flex Alert Messaging with Local Demand Response ME&O..............104. Statewide ME&O Should Support Generating Awareness on Flex Alert ..................................... 105. Utilities Will Continue Local Demand Response Notifications ....................................................... 11

F. FLEX ALERT BRAND ............................................................................................. 11G. CONCLUSION ........................................................................................................ 11H. APPENDIX A ...................................................................................................... 14

1. What Is A Flex Alert?.......................................................................................................................... 14

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A. Background

On May 10, 2012, the Commission adopted Decision (D.) 12-05-015, which provided guidance on the 2013-2014 energy efficiency portfolios and 2012 marketing, education, and outreach activities. Ordering Paragraph 117 of D.12-05-015 required Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and Southern California Gas Company (collectively, the Utilities) to file applications for statewide marketing, education, and outreach (ME&O) activities for demand-side management programs.

In D.12-05-015, the Commission stated, “we see value in continuing the emergency response portion of Flex Your Power –Flex Alert– in particular for use during hot summer months, or at any other time, when energy supplies have the potential to be tight. Emergency requests for action may be and should be connected to a larger information and education campaign, but they are fundamentally different because they are typically immediate and temporary requests for short-term conservation.”1

On August 3, 2012, the Utilities filed their applications seeking approval of statewide ME&O activities for demand-side management programs in 2013-2014. On November 8, 2012, Administrative Law Judge (ALJ) Fitch consolidated the Utilities’ applications into a single proceeding (A.12-08-007 et al).

On January 18, 2013, Assigned Commissioner Ferron and ALJ Roscow issued a ruling dividing A.12-08-007 et al into two phases. Phase 1 would address budgets for the Flex Alert program for 2013-2014; and Phase 2 would address all other aspects of the statewide marketing, education, and outreach plans for 2013-2014. On April 26, 2013, the Commission issued D.13-04-021 establishing the Utilities’ annual budgets for the Flex Alert program for 2013-2014. D.13-04-021 contained the following ordering paragraphs:

Ordering Paragraph 17 of D.13-04-021 requires that the Utilities and California Independent System Operator (CAISO) file and serve in A.12-08-007 et al., by May 17, 2013, a jointly prepared report which details how the Utilities and ISO coordinate messaging during Flex Alert events today, and how they will optimize these efforts beginning summer 2013. This report was filed and served on May 17, 2013.

Ordering Paragraph 14 of D.13-04-021 requires that SCE take the lead in initiating and coordinating an Evaluation, Measurement and Verification study of Flex Alert, measuring 2013 ex post load impacts. SCE is required to file and serve the proposal in this proceeding no later than January 31, 2014. A portion of the 2012-2014 Evaluation, Measurement and Verification budgets authorized in Decision 12-04-045 shall be used to

1 D.12-05-015, p.288-299

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fund this study. On January 28, 2014, SCE requested an extension of time to comply with OP 14, and filed and served the study on February 28, 2014.

Ordering Paragraph 16 of D.13.04.021 requires that the Utilities, CAISO, and other interested parties to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015. This proposal shall be filed and served by March 31, 2014. In compliance with Ordering Paragraph 16, this Proposal outlines the transfer of the Flex Alert program.

B. Summary of Parties’ Positions on Flex Alert Program

1. SDG&E Finds Need For an EM&V Study

In SDG&E Application (A.) 12-12-016 “Appendix X – SDG&E Response to Energy Division Guidance for Post Summer 2012 DR Evaluation and 2013/2014 Summer Planning”, SDG&E highlighted the need for a comprehensive evaluation, measurement and verification study of the Flex Alert program to determine the level of customer understanding of the differences between Flex Alert and local demand response programs, and an evaluation of the load impacts of the program. This proposal was widely supported by the Utilities. In D.13-04-021, the Commission approved the load impact study (OP 14) and stated “it is reasonable that, given the continued reliance upon Flex Alerts for urgent conservation and load reduction, the actual success of the program should be analyzed in order to support future decisions on whether to increase funding and expand the program.”2

2. SDG&E Proposed Transferring the Flex Alert Program to CAISO

SDG&E agreed with SCE’s proposal3 to transfer the administration and funding responsibilities of Flex Alert to CAISO in 2015. Since CAISO is the only entity that can issue a Flex Alert and the main purpose for issuing a Flex Alert is for statewide grid reliability, funding for this type of program should be borne by all ratepayers in the state, rather than solely Utility ratepayers. Since CAISO has load management control over investor-owned and several municipal electric utilities, CAISO may be better suited in securing funding from a broader base of ratepayers benefitting from the program.

CAISO supports the general notion of exploring different funding and administration options for the Flex Alert program but argues that the EM&V study should inform the proposal. CAISO also recommends exploring transferring responsibilities to another entity (such as the California Energy Commission), as they are concerned about the viability of available funding mechanisms.4 2 D.13-04-021, p. 21. 3 A.12-08-008, p. 25, lines 5-7 4 CAISO’s Comments on Proposed Decision Phase 1, p.3

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In D.13-04-021, the Commission found merit in the transfer proposal and stated that “it’s logical that the entity controlling the program, ISO, also be responsible for administering and securing funding for the program, and that the funding is provided by all customers who benefit from the conservation and load reduction due to Flex Alerts, not just the ratepayers of the investor-owned utilities.”5 The Commission directed SCE to work with PG&E, SDG&E, CAISO, and other interested parties to develop a transfer proposal.6

C. Flex Alert Research Findings

Several Flex Alert research studies covering process and load impact analyses have been conducted in recent program cycles.7 These studies are summarized below to help inform the Utilities’ joint recommendation to transfer the Flex Alert program.

1. 2006-2007 Flex Your Power NOW! Evaluation Report

Description: Research objectives for this evaluation report were to document the program goals and the implementation strategy for reaching them, assess customer awareness of and response to the program, assess effectiveness of program administration, assess whether the program caused a reduction in peak load, and provide guidance on whether the program should be continued in the future.

Summary: Most people understand the requested conservation actions, and end up conserving electricity, but confuse the need for conservation actions on particular days, not just particular times of day.8 Inconsistent and frequently changing program names and logos contribute to the confusion and weaken the message.9Customers see the state and utilities as the appropriate leaders of this effort and news anchors as the most compelling source of information if an event is called.10 The load impact analysis was inconclusive and Flex Alert’s contribution to the estimated 200-1100 MW system response on Flex Alert days was unclear.11

2. 2008 Flex Alert Campaign Evaluation Report

Description: This report evaluated whether recommendations from the 2006-2007 Flex Your Power NOW! Evaluation Report were implemented, evaluated the effectiveness of the campaign in increasing customer awareness, assessed what

5 D.13-04-021, p.22 6 D.13-04-021, OP 16. 7 Studies are available at www.calmac.org. 8 2006-2007 Flex Your Power NOW! Evaluation Report, p.4 9 2006-2007 Flex Your Power NOW! Evaluation Report, p.3 10 2006-2007 Flex Your Power NOW! Evaluation Report, p.6 and p.53 11 2006-2007 Flex Your Power NOW! Evaluation Report, p.5

4

conservation actions were taken and when, and determined key barriers to program participation.

Summary: Messaging consistency notably improved and 67% of respondents recalled some sort of energy conservation message (unaided) or Flex Alert with good recall of the requested actions (aided).12 However, very few respondents understood that conservation was especially needed on particular days.13 There was significant media coverage of Flex Alerts in the beginning of an event, but if an event lasted more than two days, media coverage declined considerably.14 Paid advertising was able to communicate essential details about Flex Alerts more clearly than news media coverage.15 The load impact estimate for the 2008 Flex Alert campaign was approximately 222 to 282 MW based on self-reported air conditioner and lighting behaviors. These impacts are not verified as they were based on self-reporting, without an analysis of actual energy usage.16 Furthermore, this study revisited assumptions made in the 2006-2007 load impact estimate by using more detail on timing of actions, setpoints, and building characteristics, resulting in a revision downwards from 93-495 MW to 45-75 MW.17

3. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs

Description: This study evaluated 2012 load impacts of SCE’s and SDG&E’s peak time rebate (PTR) programs and the effect of the two Flex Alert events called in 2012. SDG&E called seven PTR events in 2012, two of which occurred on the two Flex Alert days of August 10 and August 14. SCE called six PTR events, one of which was on the same day as the August 10 Flex Alert day. SDG&E included both notified and non-notified residential and small business customers, whereas SCE only included notified residential customers in the study.

Summary: SCE concluded that PTR customers who received event notifications did not respond to the Flex Alerts because the majority of the values shown are negative, indicating usage increases on Flex Alert days.18 SDG&E concluded that “there is no evidence that SDG&E’s residential or small commercial customers responded any differently on the two joint PTR and Flex Alert days than they did on the other PTR event days.”19

12 2008 Flex Alert Campaign Evaluation Report, p.7 13 2008 Flex Alert Campaign Evaluation Report, p.7 14 2008 Flex Alert Campaign Evaluation Report, p.3 15 2008 Flex Alert Campaign Evaluation Report, p.7 16 2008 Flex Alert Campaign Evaluation Report, p.9 17 2008 Flex Alert Campaign Evaluation Report, p.9 18 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs, p.1 19 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs, p.3

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4. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program

Description: The primary objectives of this study were to evaluate the ex-post load impacts of the Flex Alert program in 2013 and to develop Flex Alert program load impact estimates for the residential sector, using PG&E dynamic load profile data, and for all sectors combined using PG&E system load data.

Summary:20 Three Flex Alert event days were called in PG&E’s service territory in 2013 (April 16, July 1, and July 2), and none in the other Utilities’ service territories. The study found that no statistically significant load reductions could be attributed to the occurrence of Flex Alert event days. Both of the July Flex Alert event days coincided with event days for nearly every PG&E demand response program, which limited the ability to isolate any load reductions due to Flex Alert from the load reductions caused by the demand response programs.

The April 16 Flex Alert event was unusual due to the cause (vandalism severely damaged transformers at a substation in the San Jose area rather than a weather related event), the event was called at around midnight as opposed to the typical daytime period, and the event also activated a wide variety of PG&Es demand response programs. The April Flex Alert day applied to areas outside of PG&E’s service territory, and data is only available for PG&E’s entire service area versus the specific area affected.

5. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program

Description: The process evaluation study assessed overall understanding and awareness of Flex Alert, interviewed the implementer and stakeholder representatives, investigated media coverage, conducted comparative research, and surveyed the Flex Alert Network organization. Customer surveys (web and phone based) were completed from mid-November 2013 through mid-January 2014.

Summary: There are relatively high levels of familiarity with the term “Flex Alert” and understanding of the requested conservation actions.21 However, there is likely still confusion between Flex Alert messaging and utility-based demand response notifications.22

Paid advertising ran from June 10 through September 29, 2013 and focused primarily on the Southern California region. Television advertisements aired exclusively in Southern California as did all of the advertising in languages other than English. The Northern region’s broadcast media tactics only included spot and traffic radio. Between April 16 and September 24, 2013, 297 news items mentioned Flex Alerts.23 A large 20 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.1 21 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 22 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV 23 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76

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majority of Flex Alert earned media coverage (85%) appeared in Northern California, where all of the 2013 Flex Alert events took place.24

Earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until July 15.25 News items (earned media) generated over 8.7 million impressions in Northern California versus 820,000 in Southern California.

In general, the most frequently reported source of Flex Alert awareness was television26.Interviews with media professionals confirmed that the reporters and editors responsible for covering Flex Alerts view the events as newsworthy, primarily due to the implied potential for energy shortages to result in power outages.27 The statewide program stakeholders noted that Flex Alerts garner significant media attention. However, staff and stakeholders had differing levels of certainty around the value of the paid media campaign – while some were convinced it was necessary to keep the public aware of the brand and informed about what to do during an event, others believe the earned media might be sufficient.28

The report also notes that the differing levels of investment in Flex Alert contribute to a lack of clarity regarding program leadership and the perception that Flex Alert may be redundant to the Utilities’ local demand response programs.29

6. February 6, 2014 Flex Alert Event Media Report

On February 6, 2014, CAISO called a statewide Flex Alert event due to a natural gas shortage curtailing fuel supplies to power plants. An analysis conducted by SCE shortly thereafter shows that 21 media outlets, within the Los Angeles media market, carried the story on either February 6 or February 7, providing approximately 5 million impressions. This report confirms findings from previous studies regarding the effectiveness of earned media during events in terms of generating impressions. Important to note also is that there was no paid advertising in market at the time of this particular event. Details of the analysis:

Thirteen digital media outlets carried the story and three websites each ran two stories

Five local TV stations ran the story a total of 21 times and counted for the majority of impressions

24 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.78 25 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76 26 Process Evaluation of the 2013 Statewide Flex Alert Program, p.32 27 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 28 Process Evaluation of the 2013 Statewide Flex Alert Program, p.VI 29 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV

Deleted: plans

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Four local radio stations ran the story a total of 29 times

Media # Media Outlets # Stories Impressions

Newspaper 0 0 - Digital 13 16 126,815 TV 5 21 4,143,750Radio 3 29 702,100 Total 21 66 4,972,665

For TV and radio, the average quarter hour audience numbers for the time period when the spot ran were used to calculate the number of impressions. For digital, the average monthly visitors, divided by 30 days and then multiplied by 25% to account for the fact that not all visitors would have seen the story, was used as the calculation. The analysis did not find any newspapers that carried the story in their print editions.

7. Overall Flex Alert Research Studies Conclusions

Research studies have shown that there are relatively high levels of familiarity with the term Flex Alert and understanding of the requested conservation actions. However, there is still confusion between Flex Alert messaging and utility-based demand response notifications.

News anchors are seen as the most compelling source of information if an event is called but paid advertising was able to communicate essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until after the events. News items generated over 8.7 million impressions in Northern California and 820,000 in Southern California. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately 5 million impressions. Important to note is that there was no paid advertising in market at the time of this particular event.

Several studies have set out to measure Flex Alert load impacts and all have been either inconclusive in their findings or have provided evidence that Flex Alert’s impact is insignificant. Notable also is that SCE’s and SDG&E’s joint 2012 load impact study30 concluded that there were indications of a load increase on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two

30 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and PG&E’s Peak Time Rebate Programs

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joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR only event days.

D. Flex Alert Program Cost/Benefit Overview

The table below outlines the total annual budget, expenditures on paid media, fixed costs, agency costs, the number of Flex Alert events, and load impact (if available) per program year since 2006. [Insert conclusions – depending on info 2006-2011]

Program Year31

Annual Budget (total

for all IOUs combined)

Paid Media (total media spend for all

IOUs combined)

Fixed Costs (website,

outreach/network, production)

AgencyCosts (media

plan, buy, trafficking etc.)

Flex Alert Events32

Load Impact

(if evaluation available, in

MWs)33

2012 $10,000,00034 $7,788,166 $715,216 $1,024,633 2 n/a2013 $10,000,00035 $8,452,607 $133,000 $1,014,313 3 0

TOTAL $ $ $ $ 34 N/A

E. Flex Alert Program Transfer Proposal

1. Flex Alert Responsibilities Should Be Transferred to CAISO

As previously stated in this proposal, CAISO is the only entity that has the full scope of knowledge relative to balancing area resources within the CAISO balancing authority area to be able to initiate a Flex Alert for that area. The CAISO has load management control over both investor-owned and several municipal electric utilities for the CAISO balancing area, and the Utilities in that area have limited control over the program. However, the CAISO balancing area does not cover all of California Substantial portions are controlled by others and the intent for a statewide program would not be satisfied by a CAISO-only program. Other balancing areas in California have similar knowledge for their respective areas, but they do not currently participate in the Flex Alert program. A state-wide program was cited as being desirable. Nonetheless, the CAISO is willing and may be an appropriate entity to administer the

32 Source: http://www.caiso.com/Documents/Alert_WarningandEmergenciesRecord.pdf33 2006-2007 load impact results revised results shown in table as identified in the 2008 Flex Alert Campaign Evaluation Report. 2008 results based on self-reported air-conditioner and lighting behaviors, not verified. 2013 impact study found no statistically significant load reductions attributable to Flex Alert event days. 34 D.12-04-045, OP 19 35 D.13-04-021, OP 1, OP 2, OP 3

Commented [VPG1]: There were no costs for years 2006-2011 ?? if we have no meaningful data on costs prior to 2012, then perhaps we shouldn’t show it in a cost/benefit ratio?? Suggest deleting prior uyear data as either unavailable or inconclusive

Commented [VPG2]: Where is footnote? Could this footnote be used for stating that no data is available for previous years? And only show 2012 through 2014?

Deleted: 2006

Deleted: 18

Deleted: 45 - 75

Deleted: 2007

Deleted: 6

Deleted: 2008

Deleted: 3

Deleted: 222 - 282

Deleted: 2009

Deleted: 0

Deleted: n/a

Deleted: 2010

Deleted: 0

Deleted: n/a

Deleted: 2011

Deleted: 2

Deleted: n/a

Deleted: can

Deleted: ,

Deleted: therefore the

Deleted: and procure funding for the Flex Alert program.

9

Flex Alert program, contingent on CAISO obtaining use of the Flex Alert brand, the understanding that the program would be triggered in response to needs of the CAISO balancing area only, and regulatory approval of a mechanism for the ISO to recover its reasonable costs. The Utilities recommend that the Commission approve transferring Flex Alert program administrative responsibilities to CAISO with reasonable costs to be recovered through the utilities as approved by the Commission beginning in 2015.

These administrative responsibilities essentially translate to the CAISO continuing only its non-paid Flex Alert activities, as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.” These activities could include news bulletins, automatic notifications to subscribers via the CAISO website or its smart phone application, Twitter, Google+ and Facebook messaging. The Utilities also recommend that CAISO take over management of the Flex Alert website (www.flexalert.org) or include dedicated Flex Alert web content as part of CAISO website (www.caiso.com), assuming that the Flex Alert brand is available for CAISO use. CAISO should also manage the Flex Alert Network, as almost all organizations that participated in the Flex Alert Email Survey36 reported that an event causes them to take action, which could provide support to the overall communication activities. In addition, CAISO can work with state agencies to include the Flex Alert logo on government websites. The logo can be switched from green to red during an alert.

2. Discontinue SCE, PG&E, and SDG&E Funded Flex Alert paid advertising Campaigns

The Utilities recommend that funding for a statewide Flex Alert paid advertising campaign be discontinued. Research findings37 have found that unpaid media has proven to be effective in terms of generating consumer engagement through public service announcements or news media reports. Unpaid media is seen as the most compelling and reliable source of information when an event is called. The value of paid media has been disputed by several stakeholders and does not provide quantifiable load impacts. Eliminating the paid statewide campaign is a reasonable approach. In addition, CAISO has expressed concerns regarding lack of a funding mechanism, which creates uncertainty on how it would collect funds from non-participating electric utilities if a paid campaign were to continue or if a continuing Flex Alert program (i.e., of a reduced scope, not including paid advertisements) incurred otherwise unrecoverable costs.

36 2013 Process Evaluation of the 2013 Statewide Flex Alert Program 37 2013 Process Evaluation of the 2013 Statewide Flex Alert Program. February 6, 2014 Flex Alert Media Report

Deleted: CAISO should continue

Deleted: An example is CAISO’s Power Watch 2000 public awareness campaign, administered in previous years.

Deleted: ).

Deleted: paid

Deleted: .

10

3. Because of this, the reduced costs of the continuing program should continue to be funded through Commission approved rates to the utilities. One option that had been considered was for the CAISO to develop a funding mechanism or increase the Grid Management Charge that all CAISIO participants would pay to accommodate the increased CAISO costs for the Flex Alert program. Given that the cost of this effort, including any additional costs associated with administering the Flex Alert program, would be paid by CAISO participants, the entire effort would beunder FERC jurisdiction. This creates the risk that Market Participants who are not load-serving entities may successfully argue at FERC that such programs would not be required if additional resources were procured, or that such costs should be allocated to only load-serving entities based on principles of cost-causation. If successful, this argument would result in almost all of the funding continuing to come from California investor-owned utilities with the program now under FERC jurisdiction. Utilities Should Integrate Flex Alert Messaging with Local Demand Response ME&O

With the discontinuance of paid statewide Flex Alert activities, the Utilities will integrate Flex Alert messaging into their local demand response ME&O activities to maintain awareness of the program and support CAISO’s unpaid activities. Examples are SCE’s Summer Readiness residential brochure which includes an explanation of the difference between Save Power Day and Flex Alert, and SCE’s Summer Readiness non-residential flyer with energy saving tips and Flex Alert educational messaging

In addition, the Utilities’ Corporate Communication organizations will facilitate media coverage when a Flex Alert is issued. This integration significantly reduces the ratepayer funding needed and creates an effective opportunity to explain the differences between Flex Alerts and local demand response notifications. Integrating Flex Alert messaging with Utility-managed demand response general awareness activities can also be supported by the statewide demand response ME&O budgets, which were approved in D.13-12-038.

4. Statewide ME&O Should Support Generating Awareness on Flex Alert

The goal of the Statewide Marketing, Education and Outreach Campaign (Energy Upgrade California)38, managed by the California Center for Sustainable Energy (CCSE) for the 2014-2015 program cycle, is that “Californians understand the value of energy efficiency, demand response, and distributed generation which leads to demand for products, services and rates for their homes and businesses.”

38 D.13-12-038, p.62

11

Since generating awareness and understanding of demand response is part of the scope for this campaign, tactics such as paid media, earned/social media, website content, CBO outreach/education, and event outreach include general education about demand response and Flex Alerts. CCSE has also expressed their support for promoting Flex Alert event days in the “hero box” on the statewide Energy Upgrade California website and via social media channels.

5. Utilities Will Continue Local Demand Response Notifications

The Utilities will continue with local demand response program notifications to engage participation and achieve load reductions. In addition, given sufficient advance notice, the Utilities could dispatch certain programs when a Flex Alert is issued and change website content.

F. Flex Alert Brand

The ownership of the Flex Alert brand resides with Walter McGuire & Company, Inc. (McGuire) as of November 9, 2010.39 Continuing with this brand name, therefore, would require approval from McGuire as neither CAISO nor the Commission owns the trademark.

Research has shown40 that in the past, inconsistent and infrequently changing program names and logos were confusing and weakened the message. The Utilities therefore recommend that CAISO explore continuing with the Flex Alert brand and collaborate with McGuire in obtaining the required approvals for using the trademark.

[Insert summary conversation McGuire and CAISO about the use of the Flex Alert brand and any associated costs to be added. Meeting tentatively planned for 3/17]

G. Conclusion

The Commission has approved studies to evaluate the program’s success, and is supportive of the Utilities’ recommendation to transfer responsibility for the program to CAISO or another entity.


News anchors are seen as the most compelling source of information if an event is called but paid advertising was able to communicate essential details about the Flex 39 United States Patent and Trademark Office: Registration Number 3872849 40 2006-2007 Flex Your Power NOW! Evaluation Report

12

Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until after the events. The April 16 Flex Alert was issued in the specific northern California media markets where the event occurred. News items generated over 8.7 million impressions in Northern California and 820,000 in Southern California. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately 5 million impressions. Important to note is that there was no paid advertising in market at the time of this particular event.

Several studies have set out to measure Flex Alert load impacts and all have been either inconclusive in their findings or have provided evidence that Flex Alert’s impact is insignificant. Notable also is that SCE’s and SDG&E’s joint 2012 load impact study41 concluded that there were indications of a load increase on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR only event days.

Based on CAISO being an entity that is willing and able (contingent on a source of funding and access to the Flex Alert brand) to provide the administrative and initiation functions for Flex Alert the Utilities recommend that the Commission transfer Flex Alert program responsibilities to CAISO and discontinue any Utility-funding for paid advertisement campaign activities starting in 2015. CAISO should continue with unpaid activities only, as described in the joint Flex Alert Messaging Coordination and Optimization Report. Additionally, the CAISO should arrange to continue the administration of the Flex Alert website, manage the Flex Alert Network, and continue coordination with the state agencies.

The costs for this approach for the Flex Alert program would be significantly less than the costs incurred for the previous years due to the lack of paid advertising, but may still be more than is appropriate to incorporate into CAISO operating costs without similarly appropriate cost allocations (i.e., based on cost-causation) to utilities. Utilities’ costs for load management programs should appropriately remain under the oversight of the Commission and included within the overall Commission-approved revenue requirements. Therefore, the Utilities and the CAISO recommend that reasonable costs for the administration and implementation of the continuing Flex Alert program (i.e., notincluding paid advertisements or activities associated with securing and managing paid advertisements) remain within the oversight of the Commission.

The Utilities will integrate Flex Alert messaging as part of their local demand response marketing, education and outreach activities to support CAISO’s unpaid media activities and their Corporate Communications departments will facilitate media coverage when a Flex Alert is issued when possible. Continuance of local demand 41 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and PG&E’s Peak Time Rebate Programs

Deleted: the only entity that can initiate a Flex Alert event and having load management control over both investor-owned and several municipal electric utilities,

Deleted: funded

Deleted: (similar to the Power Watch 2000 public awareness campaign)

Deleted: ¶

13

response notifications to engage participation and achieve load reductions will provide further support.

In addition, the statewide marketing, education and outreach campaign, Energy Upgrade California, will incorporate messaging regarding the Flex Alert program into its outreach activities, as demand response education is part of the campaign’s overall goal.

Since the Flex Alert brand is owned by a third party, McGuire, CAISO should collaborate with McGuire in seeking the required approvals to use the trademark. [Insert conclusion conversation McGuire and CAISO]

The Utilities respectfully request that the Commission issue a Proposed Decision based on this proposal in order for all Parties to submit comments. A Final Decision should then be issued thereafter, taking into consideration all comments.

The Utilities are confident that this Flex Alert transfer proposal meets the requirements of Ordering Paragraph 16 of D.13.04.021 set forth by the Commission and satisfies the program stakeholders involved.

Deleted: obtaining

Deleted: ¶¶¶¶

14

H. APPENDIX A

1. What Is A Flex Alert?

The “Flex Alert Messaging Coordination and Optimization Report for Summer 2013,” filed by the Utilities on May 17, 2013, describes Flex Alert as follows:

“A Flex Alert is an urgent call to Californians to immediately conserve electricity and shift demand to off-peak hours (after 6 p.m.). The Flex Alert campaign is an educational and emergency alert program that informs consumers about how and when to conserve electricity. The public awareness campaign is critical to achieving conservation during heat waves and other challenging grid conditions such as wildfires or when major power plant or power lines are unavailable. Flex Alerts also inform the public about the potential for service interruptions, giving customers the opportunity to conserve electricity to help prevent blackouts from occurring. The ISO typically issues a Flex Alert when there is potential for an electrical emergency (due to decreased operating reserves) or a transmission emergency (due to power line limitations).

Exhibit 2

1

David Lowrey

From: Roland Mollen <[email protected]>Sent: Friday, April 17, 2015 2:33 PMTo: David LowreySubject: Fw: Flex Alert Transfer Proposal - V6.1Attachments: Flex Alert Transfer Proposal - V6.1.docx

Follow Up Flag: Follow upFlag Status: Flagged

Here's a later version than the one I'd sent you before with one page nine the following sentence:

These administrative responsibilities essentially translate to the CAISO continuing only its non-paid Flex Alert activities, as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.”

Roland Mollen, MBA Project ManagerDSM Strategy & Policy Southern California Edison Desk: (626) 302 0855 PAX 20855Cell: (909) 471-0918

Follow SCE: SCE.com | LinkedIn | Twitter | YouTube----- Forwarded by Roland Mollen/SCE/EIX on 04/17/2015 02:31 PM -----

From: "Van Pelt, Gregory" <[email protected]>To: "[email protected]" <[email protected]>, Date: 03/27/2014 04:56 PMSubject: Flex Alert Transfer Proposal - V6.1

Roland,

Thank you very much for your patience.

Here is the version the ISO is submitting for your review and filing with the CPUC.

I will be out of the office tomorrow, but you can direct any questions or concerns directly to Anna McKenna (copied on this note) who is the ISO attorney most responsible for the version attached.

2

Thank you again for your understanding and indulgence.

Best,

Gregory Van Pelt

Office: 916-351-2190 Cell: 916-802-9133


If you have received this electronic message in error, please notify the sender immediately. The foregoing e-mail communication (together with any attachments thereto) is intended for the designated recipient(s) only. Its terms are confidential and may be protected by the attorney/client, or other applicable, privilege. If you are not the intended recipient, you are hereby notified that any use, disclosure, copying, distribution (electronic or otherwise), or taking any action in reliance on the contents of this information is strictly prohibited.

*********************************************************************************************The foregoing electronic message, together with any attachments thereto, is confidential and may be legally privileged against disclosure other than to the intended recipient. It is intended solely for the addressee(s) and access to the message by anyone else is unauthorized. If you are not the intended recipient of this electronic message, you are hereby notified that any dissemination, distribution, or any action taken or omitted to be taken in reliance on it is strictly prohibited and may be unlawful. If you have received this electronic message in error, please delete and immediately notify the sender of this error. *********************************************************************************************(See attached file: Flex Alert Transfer Proposal - V6.1.docx)


Table of Contents

A. BACKGROUND ........................................................................................................ 1B. SUMMARY OF PARTIES’ POSITIONS ON FLEX ALERT PROGRAM .................................. 2

1. SDG&E Highlights the Need For an EM&V Study ............................................................................ 22. SDG&E Proposed Transferring the Flex Alert Program to CAISO ................................................. 2

C. FLEX ALERT RESEARCH FINDINGS ........................................................................... 31. 2006-2007 Flex Your Power NOW! Evaluation Report .................................................................... 32. 2008 Flex Alert Campaign Evaluation Report ................................................................................... 33. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and

SDG&E’s Peak Time Rebate Programs ............................................................................................ 44. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program ...........................55. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program ............................................. 56. February 6, 2014 Flex Alert Event Media Report.............................................................................. 67. Overall Flex Alert Research Studies Conclusions ............................................................................ 7

D. FLEX ALERT PROGRAM COST/BENEFIT OVERVIEW ................................................... 8E. FLEX ALERT PROGRAM TRANSFER PROPOSAL ......................................................... 9

1. Flex Alert Responsibilities Should Be Transferred to CAISO .......................................................... 92. Discontinue SCE, PG&E, and SDG&E Funded Flex Alert paid advertising Campaigns ............103. CAISO Should Recover Reasonable Administration Costs through Purchase Order

Agreements with Utilities ................................................................................................................... 104. Utilities Should Integrate Flex Alert Messaging with Local Demand Response ME&O..........10115. Statewide ME&O Should Support Generating Awareness on Flex Alert .....................................116. Utilities Will Continue Local Demand Response Notifications ................................................... 1112

F. EXPLORATION OF ALTERNATIVE ENTITIES............................................................... 12G. FLEX ALERT BRAND ............................................................................................. 13H. CONCLUSION ........................................................................................................ 14I. APPENDIX A .................................................................................................. 1716

1. What Is A Flex Alert?...................................................................................................................... 1716

1

A. Background

On May 10, 2012, the Commission adopted Decision (D.) 12-05-015, which provided guidance on the 2013-2014 energy efficiency portfolios and 2012 marketing, education, and outreach activities. Ordering Paragraph 117 of D.12-05-015 required Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and Southern California Gas Company (collectively, the Utilities) to file applications for statewide marketing, education, and outreach (ME&O) activities for demand-side management (DSM) programs.

In the decision, the Commission stated, “we see value in continuing the emergency response portion of Flex Your Power –Flex Alert– in particular for use during hot summer months, or at any other time, when energy supplies have the potential to be tight. Emergency requests for action may be and should be connected to a larger information and education campaign, but they are fundamentally different because they are typically immediate and temporary requests for short-term conservation.”1


On January 18, 2013, Assigned Commissioner Ferron and ALJ Roscow issued a ruling dividing A.12-08-007 et al into two phases. Phase 1 would address budgets for the Flex Alert program for 2013-2014; and Phase 2 would address all other aspects of the statewide marketing, education, and outreach plans for 2013-2014. On April 26, 2013, the Commission issued D.13-04-021 establishing the Utilities’ annual budgets for the Flex Alert program for 2013-2014. D.13-04-021 contained the following ordering paragraphs:

Ordering Paragraph (OP) 17 of D.13-04-021 requires that the Utilities and California Independent System Operator (CAISO) file and serve in A.12-08-007 et al., by May 17, 2013, a jointly prepared report which details how the Utilities and ISO coordinate messaging during Flex Alert events today, and how they will optimize these efforts beginning summer 2013. This report was filed and served on May 17, 2013.

OP 14 of D.13-04-021 requires that SCE take the lead in initiating and coordinating an Evaluation, Measurement and Verification study of Flex Alert, measuring 2013 ex post load impacts. SCE is required to file and serve the proposal in this proceeding no later than January 31, 2014. A portion of the 2012-2014 Evaluation, Measurement and Verification

1 D.12-05-015, p.288-299

2

budgets authorized in Decision 12-04-045 shall be used to fund this study. On January 28, 2014, SCE requested an extension of time to comply with OP 14, and filed and served the study on February 28, 2014.

OP 16 of D.13.04.021 requires that the Utilities, CAISO, and other interested parties to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015. This proposal shall be filed and served by March 31, 2014. In compliance OP 16, this Proposal outlines the transfer of the Flex Alert program.

B. Summary of Parties’ Positions on Flex Alert Program

1. SDG&E Highlights the Need For an EM&V Study

In SDG&E Application (A.) 12-12-016 “Appendix X – SDG&E Response to Energy Division Guidance for Post Summer 2012 DR Evaluation and 2013/2014 Summer Planning”, SDG&E highlighted the need for a comprehensive evaluation, measurement and verification study of the Flex Alert program to determine the level of customer understanding of the differences between Flex Alert and local demand response programs, and an evaluation of the load impacts of the program. This proposal was widely supported by the Utilities. In D.13-04-021, the Commission approved the load impact study (OP 14) and stated “it is reasonable that, given the continued reliance upon Flex Alerts for urgent conservation and load reduction, the actual success of the program should be analyzed in order to support future decisions on whether to increase funding and expand the program.”2


SDG&E agreed with SCE’s proposal3 to transfer the administration and funding responsibilities of Flex Alert to CAISO in 2015. Since CAISO is the only entity that can issue a Flex Alert, and the main purpose for issuing a Flex Alert is for statewide grid reliability, funding for this type of program should be borne by all ratepayers in the state, rather than solely Utility ratepayers. Since CAISO has load management control over investor-owned and several municipal electric utilities, CAISO may be better suited in securing funding from a broader base of ratepayers benefitting from the program.

CAISO supporteds the general notion of exploring different funding and administration options for the Flex Alert program but argueds that the EM&V study should inform the proposal. CAISO also recommendeds exploring transferring responsibilities to another entity (such as the California Energy Commission), as they are concerned about the viability of available funding mechanisms.4 2 D.13-04-021, p. 21. 3 A.12-08-008, p. 25, lines 5-7 4 CAISO’s Comments on Proposed Decision Phase 1, p.3

3

In D.13-04-021, the Commission found merit in the transfer proposal and stated that “it’s logical that the entity controlling the program, ISO, also be responsible for administering and securing funding for the program, and that the funding is provided by all customers who benefit from the conservation and load reduction due to Flex Alerts, not just the ratepayers of the investor-owned utilities.”5 The Commission directed SCE to work with PG&E, SDG&E, CAISO, and other interested parties to develop a transfer proposal.6

C. Flex Alert Research Findings

Several Flex Alert research studies covering process and load impact analyses have been conducted in recent program cycles.7 These studies are summarized below to help inform the Utilities’ joint recommendation to transfer the Flex Alert program.



Summary: Most people understand the requested conservation actions, and end up conserving electricity, but confuse the need for conservation actions on particular days, not just particular times of day.8 Inconsistent and frequently changing program names and logos contribute to the confusion and weaken the message.9Customers see the state and utilities as the appropriate leaders of this effort and news anchors as the most compelling source of information if an event is called.10 The load impact analysis was inconclusive and Flex Alert’s contribution to the estimated 200-1100 MW system response on Flex Alert days was unclear.11


Description: This report evaluated whether recommendations from the 2006-2007 Flex Your Power NOW! Evaluation Report were implemented, evaluated the effectiveness of the campaign in increasing customer awareness, assessed what

5 D.13-04-021, p.22 6 D.13-04-021, OP 16. 7 Studies are available at www.calmac.org.8 2006-2007 Flex Your Power NOW! Evaluation Report, p.4 9 2006-2007 Flex Your Power NOW! Evaluation Report, p.3 10 2006-2007 Flex Your Power NOW! Evaluation Report, p.6 and p.53 11 2006-2007 Flex Your Power NOW! Evaluation Report, p.5

4

conservation actions were taken and when, and determined key barriers to program participation.

Summary: Messaging consistency notably improved and 67% of respondents recalled some sort of energy conservation message (unaided) or Flex Alert with good recall of the requested actions (aided).12 However, very few respondents understood that conservation was especially needed on particular days.13 There was significant media coverage of Flex Alerts in the beginning of an event, but if an event lasted more than two days, media coverage declined considerably.14 Paid advertising was able to communicate essential details about Flex Alerts more clearly than news media coverage.15 The load impact estimate for the 2008 Flex Alert campaign was approximately 222 to 282 MW based on self-reported air conditioner and lighting behaviors. These impacts are not verified as they were based on self-reporting, without an analysis of actual energy usage.16 Furthermore, this study revisited assumptions made in the 2006-2007 load impact estimate by using more detail on timing of actions, setpoints, and building characteristics, resulting in a revision downwards from 93-495 MW to 45-75 MW.17


Description: This study evaluated 2012 load impacts of SCE’s and SDG&E’s peak time rebate (PTR) programs and the effect of the two Flex Alert events called in 2012. SDG&E called seven PTR events in 2012, two of which occurred on the two Flex Alert days of August 10 and August 14. SCE called six PTR events, one of which was on the same day as the August 10 Flex Alert day. SDG&E included both notified and non-notified residential and small business customers, whereas SCE only included notified residential customers in the study.


12 2008 Flex Alert Campaign Evaluation Report, p.7 13 2008 Flex Alert Campaign Evaluation Report, p.7 14 2008 Flex Alert Campaign Evaluation Report, p.3 15 2008 Flex Alert Campaign Evaluation Report, p.7 16 2008 Flex Alert Campaign Evaluation Report, p.9 17 2008 Flex Alert Campaign Evaluation Report, p.9 18 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs, p.1 19 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and SDG&E’s Peak Time Rebate Programs, p.3

5



Summary:20 Three Flex Alert event days were called in PG&E’s service territory in 2013 (April 16, July 1, and July 2), and none in the other Utilities’ service territories. The study found that no statistically significant load reductions could be attributed to the occurrence of Flex Alert event days. Both of the July Flex Alert event days coincided with event days for nearly every PG&E demand response program, which limited the ability to isolate any load reductions due to Flex Alert from the load reductions caused by the demand response programs.

The April 16 Flex Alert event was unusual due to the cause (vandalism severely damaged transformers at a substation in the San Jose area rather than a weather-related event), the event was approximately called at midnight as opposed to the typical daytime period, and the event also activated a wide variety of PG&E’s demand response programs. The April Flex Alert day applied to areas outside of PG&E’s service territory, and data is only available for PG&E’s entire service area versus the specific area affected.

5. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program21



Paid advertising ran from June 10 through September 29, 2013 and focused primarily on the Southern California region. Television advertisements aired exclusively

20 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.1 21 At the time of this filing of the Flex Alert Transfer Proposal, the 2013 Process Evaluation study is a draft document and not yet finalized and should be considered preliminary in its findings. The study is currently in review by the Demand Response M&E Committee, SCE, SDG&E, PG&E, Energy Division and the CEC. The draft study can be found on sce.com/……………..22 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 23 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV

Commented [MR1]: SCE to insert URL

6

in Southern California as did all of the advertising in languages other than English. The Northern region’s broadcast media tactics only included spot and traffic radio. Between April 16 and September 24, 2013, 297 news items mentioned Flex Alerts.24 A large majority of Flex Alert earned media coverage (85%) appeared in Northern California, where all of the 2013 Flex Alert events took place.25

Earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until July 15.26 News items (earned media) generated over 8.7 million impressions in Northern California versus 820,000 in Southern California.

In general, the most frequently reported source of Flex Alert awareness was television27. Interviews with media professionals confirmed that the reporters and editors responsible for covering Flex Alerts view the events as newsworthy, primarily due to the implied potential for energy shortages to result in power outages.28 The statewide program stakeholders noted that Flex Alerts garner significant media attention. However, staff and stakeholders had differing levels of certainty around the value of the paid media campaign – while some were convinced it was necessary to keep the public aware of the brand and informed about what to do during an event, others believe the earned media might be sufficient.29



On February 6, 2014, CAISO called a statewide Flex Alert event due to a natural gas shortage curtailing fuel supplies to power plants. An analysis conducted by SCE shortly thereafter of Flex Alert media coverage in Southern, Central, and Northern California media markets shows that 79 media outlets carried the story on either February 6 or February 7, providing approximately 9 million impressions. This report confirms findings from previous studies regarding the effectiveness of earned media during events in terms of generating impressions. Important to note also is that there was no paid advertising in market at the time of this particular event. Details of the analysis:

24 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76 25 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.78 26 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76 27 Process Evaluation of the 2013 Statewide Flex Alert Program, p.32 28 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 29 Process Evaluation of the 2013 Statewide Flex Alert Program, p.VI 30 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV

7

Southern California:



Three local radio stations ran the story a total of 29 times

Northern and Central California:

Twenty four digital media outlets carried the story

Twenty six local TV stations ran the story a total of 79 times

Eight newspapers printed the story a total of 8 times

For TV and radio, the average quarter hour audience numbers for the time period when the spot ran were used to calculate the number of impressions. For digital, the average monthly visitors, divided by 30 days and then multiplied by 25% to account for the fact that not all visitors would have seen the story, was used as the calculation. The analysis did not find any newspapers that carried the story in their print editions for the Southern California media market.



Media # Media Outlets # Stories # ImpressionNewspaperDigital 13 16 126,815TV 5 21 4,143,750

Radio 3 29 702,100Total 21 66 4,972,665

Media # Media Outlets # Stories # ImpressionNewspaper 8 8 1,778,503Digital 24 24 254,597TV 26 79 1,777,682

RadioTotal 58 111 3,810,782

8

News anchors are seen as the most compelling source of information if an event is called but paid advertising was able to communicate essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until after the events. News items generated over 8.7 million impressions in Northern California and 820,000 in Southern California. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately 5 million impressions. Important to note is that there was no paid advertising in market at the time of this particular event.

Several studies have set out to measure Flex Alert load impacts and all have been inconclusive in their findings. Notable also is that SCE’s and SDG&E’s joint 2012 load impact study31 concluded that there were indications of a load increase on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR only event days.

D. Flex Alert Program Cost/Benefit Overview

The table below outlines the total annual budget, expenditures on paid media, fixed costs, agency costs, the number of Flex Alert events, and load impact (if available) per program year since 2006. The Flex Alert program budget from 2006 to 2013 totals $62 million with 35 events having been called during this time frame and no conclusive load impacts.

Program Year

Annual Budget (total

for all IOUs combined)32

Paid Media (total media spend for all

IOUs combined)

Fixed Costs (website,

outreach/network, production)

AgencyCosts (media


Flex Alert Events33

Load Impact


MWs)34

2006 $6,649,247

Data not provided35

18 45 - 75 2007 $6,650,076 6 2008 $6,650,896 3 222 - 282 2009 $5,477,273 0 n/a2010 $4,200,292 0 n/a

31 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and PG&E’s Peak Time Rebate Programs 32 Budgets 2006-2008: D.06-03-024, OP 1. Budgets 2009-2011: D.09-08-027, OP 17. Budget 2012: D.12-04-045, OP 19. Budgets 2013-2014: D.13-04-021, OP 1, OP 2, OP 3. 33 Source: http://www.caiso.com/Documents/Alert_WarningandEmergenciesRecord.pdf34 2006-2007 load impact results revised results shown in table as identified in the 2008 Flex Alert Campaign Evaluation Report. 2008 results based on self-reported air-conditioner and lighting behaviors, not verified. 2013 impact study found no statistically significant load reductions attributable to Flex Alert event days. 35 PG&E Flex Alert statewide program lead from 2006-2010

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2011 $2,929,311 $2,584,945 $97,000 $311,004 2 n/a2012 $10,000,000 $7,788,166 $715,216 $1,024,633 2 n/a2013 $10,000,000 $8,452,607 $133,000 $1,014,313 3 0 2014 $10,000,000 n/a n/a n/a 1 0

TOTAL $62,557,095 Inconclusive Inconclusive Inconclusive 35 n/a

E. Flex Alert Program Transfer Proposal

1. Flex Alert Responsibilities Should Be Transferred to CAISO

CAISO has the scope of knowledge relative to balancing area resources within their authority area, and can initiate a Flex Alert specifically for that area. The CAISO has generation-load balancing management control over both investor-owned and several municipal electric utilities for the CAISO balancing area, and the Utilities in that area have limited control over the issuance of the Flex Alertprogram. However, the CAISO balancing area does not cover all of California. Substantial portions are controlled by others and the intent for a statewide program would not be satisfied by a CAISO-only program. Other balancing areas in California have similar knowledge for their respective areas, but they do not currently participate in the Flex Alert program (albeit they may benefit from spillover Flex Alert messaging). A state-wide program was cited as being desirable. Nonetheless, the CAISO has expressed a is willingness and is an appropriate entity to administer the Flex Alert program, contingent on the CAISO’sability to useobtaining use of the Flex Alert brand, the understanding that the program would be triggered in response to needs of the CAISO balancing area only, and theCPUC finding that the program should be continued and authorizing the Utilities to fund the program and contract with the CAISO so that obtaining regulatory approval of a mechanism for the CAISO can to recover its reasonable costs. The Utilities recommend that the Commission approve transferring Flex Alert program administrative responsibilities to CAISO with reasonable costs to be recovered through the utilities as approved by the Commission beginning in 2015.

These administrative responsibilities essentially translate to the CAISO continuing only its non-paid Flex Alert activities, as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.” These activities could include news bulletins, automatic notifications to subscribers via the CAISO website or its smart phone application, Twitter, Google+ and Facebook messaging. The Utilities also recommend that CAISO take over management of the Flex Alert website (www.flexalert.org) or include dedicated Flex Alert web content as part of CAISO website (www.caiso.com), assuming that the Flex Alert brand is available for CAISO use. CAISO should also manage the Flex Alert Network, as almost all organizations that participated in the Flex Alert Email Survey36 reported that an event causes them to take action, which could provide support to the overall communication activities. In addition, CAISO can work with state agencies to include the Flex Alert logo on government websites. The logo can be switched from green to red during an alert. 36 2013 Process Evaluation of the 2013 Statewide Flex Alert Program

Formatted: Not Highlight


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2. Discontinue SCE, PG&E, and SDG&E Funded Flex Alert paid advertising Campaigns

The Utilities recommend that funding for a statewide Flex Alert paid advertising campaign be discontinued. Research findings37 have found that unpaid media has proven to be effective in terms of generating consumer engagement through public service announcements or news media reports. Unpaid media is seen as the most compelling and reliable source of information when an event is called. The value of paid media has been disputed by several stakeholders and does not provide quantifiable load impacts. Eliminating the paid statewide campaign is a reasonable approach. In addition, CAISO has expressed concerns regarding lack of a funding mechanism, which creates uncertainty on how it would collect funds from non-participating electric utilities if a paid campaign were to continue or if a continuing Flex Alert program (i.e., of a reduced scope, not including paid advertisements) incurred otherwise unrecoverable costs.

Although the statewide paid advertising campaign would be discontinued, the Utilities and CAISO recommend leveraging the existing brand equity and funding for minimal activities such as website maintenance, trademark protection, and continuation of the Flex Alert network through CPUCCommission- approved rates.

3. CAISO Should Recover Reasonable Administration Costs from the Utilities Leveraging Existing Funding As Approved by the CPUC

Several options have been considered for cost recovery with administering the Flex Alert program. The preferred approach for cost recovery option is for the CPUC to approve CAISO to develop a funding mechanism, which leverages the existing Flex Alert funding approach and establishes the funding levels. at amounts approved by the CPUC. An example would be for the CAISO to enter into an agreement with each of the Utilities whereby the CAISO would submit a timely invoice to each Utility to recover costs within the scope of the activities identified in section E.1 of this proposal. CAISO would be responsible for recovering costs per an agreed upon percentage or amount with each Utility. In this example the agreement between CAISO and the Utilities should include a description of the scope of work and the total available funding not to exceed amounts authorized by the CPUC through a regulatory proceeding such as the Statewide Marketing, Education & Outreach (SW ME&O) application.

An option to fund the program through an increase in the CAISO Grid

Management Charge was explored but was not preferred by CAISO. CAISO believes that this approach creates the risk that Market Participants who are not load-serving entities may successfully argue at FERC that such programs would not be required if additional resources were procured, or that such costs should be allocated to only load-serving entities based on principles of cost-causation. If successful, this argument

37 2013 Process Evaluation of the 2013 Statewide Flex Alert Program. February 6, 2014 Flex Alert Media Report

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would result in essentially all of the funding continuing to come from California investor-owned utilities, but with the program now under FERC jurisdiction.

4. Utilities Should Integrate Flex Alert Messaging with Local Demand Response ME&O

With the discontinuance of paid statewide Flex Alert activities, the Utilities will integrate Flex Alert messaging into their local demand response ME&O activities to maintain awareness of the program and support CAISO’s unpaid activities. Examples include SCE’s Summer Readiness residential brochure which includes an explanation of the difference between Save Power Day and Flex Alert, and SCE’s Summer Readiness non-residential flyer with energy saving tips and Flex Alert educational messaging

In addition, the Utilities’ Corporate Communication organizations will facilitate media coverage when a Flex Alert is issued. This integration significantly reduces the ratepayer funding needed and creates an effective opportunity to explain the differences between Flex Alerts and local demand response notifications. Integrating Flex Alert messaging with Utility-managed demand response general awareness activities can also be supported by the statewide demand response ME&O budgets, which were approved in D.13-12-038.

5. Statewide ME&O Should Support Generating Awareness on Flex Alert

The goal of the Statewide Marketing, Education and Outreach Campaign (Energy Upgrade California), managed by the California Center for Sustainable Energy (CCSE) for the 2014-2015 program cycle, is that “Californians understand the value of energy efficiency, demand response, and distributed generation which leads to demand for products, services and rates for their homes and businesses.”38

Since generating awareness and understanding of demand response is part of the scope for this campaign, tactics such as paid media, earned/social media, website content, CBO outreach/education, and event outreach include general education about demand response and Flex Alerts. CCSE has also expressed their support for promoting Flex Alert event days in the “hero box” on the statewide Energy Upgrade California website and via social media channels.


The Utilities will continue with local demand response program notifications to engage participation and achieve load reductions. In addition, given sufficient advance

38 D.13-12-038, p.62

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notice, the Utilities could dispatch certain programs when a Flex Alert is issued and change website content.

F. Exploration of Alternative Entities

The Utilities considered the California Energy Commission (CEC) as an alternative entity to administer the Flex Alert program in its preparation for this transfer proposal. However, after a preliminary review, the Utilities concluded that a transfer to the CEC would mean exploring an unknown and potentially complex funding structure that may take a lengthy time to construct, adding an additional entity who would need to coordinate with CAISO as they are the only entity who can initiate a Flex Alert in their balancing area, and uncertainty whether or not CEC can or is willing to take over the responsibilities for this statewide program. Furthermore, CAISO, in constructive and collaborative conversations with the Utilities, expressed support for accepting toadminister the lead role for the Flex Alert program and becauseas they were the only party who had recommended exploring additional entities, the Utilities did not engage in discussions with the CEC.

A second alternative entity is the California Utilities Emergency Association (CUEA). CUEA serves as a point-of-contact for critical infrastructure utilities and the California Office of Emergency Services (Cal OES) and other Governmental Agencies before, during and after an event to39:

Facilitate communications and cooperation between member utilities and public agencies; and with non-member utilities (where resources and priorities allow);

Provide emergency response support wherever practical for electric, petroleum pipeline, telecommunications, gas, water and wastewater utilities and;

Support utility emergency planning, mitigation, training, exercises and education.

This organization was recently brought to the Utilities’ attention as an alternative entity for taking on the statewide responsibility for the Flex Alert program and has been approached in the final stage of filing the transfer proposal. Due to the limited opportunity for CUEA to provide input, we have not been able to incorporate it. However, we have made CUEA aware of this proceeding and informed them of the opportunity to review and comment if they elect to do so.

39 Source: www.cueainc.com

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G. Flex Alert Brand

The ownership of the Flex Alert brand resides with Walter McGuire & Company, Inc. (McGuire) as of November 9, 2010.40 Continuing with this brand name, therefore, would require approval from McGuire as neither CAISO nor the Commission owns the trademark.

Research has shown41 that in the past, inconsistent and infrequently changing program names and logos were confusing and weakened the message. The Utilities therefore recommend that CAISO explore continuing with the Flex Alert brand and collaborate with McGuire in obtaining the required approvals for using the trademark.

SCE facilitated a meeting on March 17, 2014 for CAISO and McGuire in which the following topics were covered regarding the Flex Alert brand:

1. Use of the brand/ownership: McGuire confirmed that there are currently no costs for CAISO or IOUs to

use the brand, which will be confirmed in writing. Transferring the ownership of the brand to another entity is also an option that could be explored.

2. Administration: McGuire stated that trademark protection activities should continue in

order to ensure that the brand is not misused or forfeited. McGuire, as the current owner of the brand, has traditionally provided this service as a part of implementing the Flex Alert campaign. Costs for continuing this service would need to be determined if the campaign, or any part of it, is transferred to another entity.

3. Website: McGuire has developed and maintained the current program website,

www.flexalert.org. The annual costs varied depending on the type of activities that were required.

CAISO and McGuire agreed that a contract would be required if this activity were to continue in its current form in 2015.

4. Flex Alert Network: McGuire maintains a database which is updated annually by contacting

each member by phone to ensure accuracy of contact information. Network members are alerted through e-blasts which are distributed by

McGuire. Transferring the e-blast responsibilities to another entity, such as the CAISO, would require a review of the agreements McGuire holds with the Network members to identify if this would be allowed.

40 United States Patent and Trademark Office: Registration Number 3872849 41 2006-2007 Flex Your Power NOW! Evaluation Report

14

The CAISO and McGuire agreed to continue their collaboration to explore activities and associated costs should the Flex Alert program responsibilities transfer to CAISO starting in 2015.

In discussions with McGuire, the Utilities requested assignment of brand ownership to the State of California, to which McGuire was amendable. Therefore the Utilities recommend that the CPUC requests McGuire for an immediate transfer of the Flex Alert brand to the State of California.

H. Conclusion

The Commission has approved studies to evaluate the program’s success, and as stated above, is supportive of the Utilities’ recommendation to transfer responsibility for the program to CAISO or another entity.


News anchors are seen as the most compelling source of information if an event is called but paid advertising was able to communicate essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. There was no paid media in market at the time of the April event day and during the July event days, only the program’s traffic radio sponsorships had launched in Northern California with the full campaign not being in place until after the events. The April 16 Flex Alert was issued in the specific northern California media markets where the event occurred. News items generated over 8.7 million impressions in Northern California and 820,000 in Southern California. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately 5 million impressions. Important to note is that there was no paid advertising in market at the time of this particular event.

Several studies have set out to measure Flex Alert load impacts and all have been inconclusive in their findings. Notable also is that SCE’s and SDG&E’s joint 2012 load impact study42 concluded that there were indications of a load increase on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR only event days.


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Based on CAISO being an entity that is willing and able (contingent on a source of funding and access to the Flex Alert brand) to provide the administrative and initiation functions for Flex Alert, the Utilities recommend that the Commission transfer Flex Alert program responsibilities to CAISO. The Utilities also recommend that the CPUC and discontinue any Utility-funding for paid Flex Alert advertisement campaign activities starting in 2015. The CAISO should continue with unpaid activities only, as described in the joint Flex Alert Messaging Coordination and Optimization Report. Additionally, theCAISO should arrange to continue the administration of the Flex Alert website, manage the Flex Alert Network, and continue coordination with the state agencies.

The costs for this approach for the Flex Alert program would be significantly less than the costs incurred for the previous years due to the lack of paid advertising, but may still be more than is appropriate to incorporate into CAISO operating costs without similarly appropriate cost allocations (i.e., based on cost-causation) to utilities. The Utilities and the CAISO recommend that reasonable costs for the administration and implementation of continuing the Flex Alert program (i.e., not including paid advertisements or activities associated with securing and managing paid advertisements) remain within the oversight of the CPUCCommission. The preferred cost recovery approach option is for the CPUC to approve CAISO to develop a funding mechanism which leverages the existing Flex Alert funding approach and establishes the funding levels for the program. at amounts approved by the CPUC.

The Utilities will integrate Flex Alert messaging as part of their local demand response marketing, education and outreach activities to support CAISO’s unpaid media activities and their Corporate Communications departments will facilitate media coverage when a Flex Alert is issued when possible. Continuance of local demand response notifications to engage participation and achieve load reductions will provide further support.

In addition, the statewide marketing, education and outreach campaign, Energy Upgrade California, will incorporate messaging regarding the Flex Alert program into its outreach activities, as demand response education is part of the campaign’s overall goal.

Since the Flex Alert brand is owned by a third party, McGuire, CAISO should collaborate with McGuire in seeking the required approvals to use the trademark. SCE facilitated a meeting on March 17, 2014 for CAISO and McGuire to discuss several key topics regarding usage of the Flex Alert brand and associated administrative activities. McGuire confirmed that there would be no cost for the usage of the brand. The only costs that would apply are in regards to administrative expenses for e.g. maintaining the program website, trademark protection, and transferring Flex Alert Network related outreach activities. CAISO and McGuire agreed to continue their collaboration to explore activities and associated costs should the Flex Alert program responsibilities transfer to CAISO starting in 2015.


16

The Utilities respectfully request that the Commission issue a Proposed Decision based on this proposal in order for all Parties to submit comments. A Final Decision should then be issued thereafter, taking into consideration all comments.

The Utilities are confident that this Flex Alert transfer proposal meets the requirements of OP 16 of D.13.04.021 set forth by the Commission and satisfies the program stakeholders involved.

17

I. APPENDIX A




Exhibit 3

1

Andrea Tozer

From: Roland MollenSent: Friday, July 31, 2015 10:59 AMTo: Andrea TozerSubject: FW: Final review: Flex Alert Transfer ProposalAttachments: Flex Alert Transfer Proposal - V12.docx

Found the 3/28 email

Roland MollenProject ManagerDSM Policy & ComplianceSouthern California EdisonDesk: (626) 302 0855 PAX 20855Cell: (909) 471 0918


From: Roland Mollen [mailto:[email protected]]Sent:Monday, June 15, 2015 7:25 AMTo: David LowreyCc: Roland MollenSubject: Fw: Final review: Flex Alert Transfer Proposal

3/28 email with attachment


Follow SCE: SCE.com | LinkedIn | Twitter | YouTube----- Forwarded by Roland Mollen/SCE/EIX on 06/15/2015 07:24 AM -----

From: Roland Mollen/SCE/EIXTo: "Yip, Andrew" <[email protected]>, "Long, Lisa" <[email protected]>, "Agustin, Melody" <[email protected]>, [email protected],[email protected], [email protected], "McKenna, Anna" <[email protected]>, "Van Pelt, Gregory" <[email protected]>,Cc: Andrea Tozer/SCE/EIX@SCE, David Lowrey/SCE/EIX@SCE, Aimee Wong/SCE/EIX@SCE, Michelle Thomas/SCE/EIX, Brian Kopec/SCE/EIX@SCEDate: 03/28/2014 04:51 PMSubject: Final review: Flex Alert Transfer Proposal

FOR INTERNAL USE ONLY

All,

2

Thanks for your patience! It took a bit longer than expected unfortunately to edit the proposal for your final review. Rather than writing a lengthy email explaining what we have changed, take a look at the attached and it should be fairly straightforward. We've opted not to send it in tracked changes since we've added an Executive Summary, revised section E, and eliminated the Conclusion (seemed duplicative with an Executive Summary). These changes would make it unreadable to you so we've attached a clean version instead. Other changes throughout the report in other sections are relatively minor.

The main conclusion that we've reached is that if the recommendations (described in the Executive Summary) are accepted, then there's no need for any funding anymore. We believe that these recommendations are reasonable and should result in an orderly transfer of the program to CAISO, who's collaboration and flexibility in our conversations are much appreciated.

(See attached file: Flex Alert Transfer Proposal - V12.docx)

Kind request to submit your comments and/or edits by 11:00 Monday 3/31. Thanks!

Roland Mollen Project ManagerDSM Strategy & Policy Southern California Edison Desk: (626) 302 0855 PAX 20855Cell: (909) 471-0918




Table of Contents

A. EXECUTIVE SUMMARY ............................................................................................. 1B. BACKGROUND ........................................................................................................ 1C. SUMMARY OF PARTIES’ POSITIONS ON FLEX ALERT PROGRAM .................................. 2

1. SDG&E Highlights the Need for an EM&V Study ............................................................................... 22. SDG&E Proposed Transferring the Flex Alert Program to CAISO ...................................................3

D. FLEX ALERT RESEARCH FINDINGS ........................................................................... 31. 2006-2007 Flex Your Power NOW! Evaluation Report ...................................................................... 42. 2008 Flex Alert Campaign Evaluation Report ..................................................................................... 43. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and

SDG&E’s Peak Time Rebate Programs .............................................................................................. 54. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program ............................55. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program ..............................................66. February 6, 2014 Flex Alert Event Media Report................................................................................ 87. Overall Flex Alert Research Studies Conclusions .............................................................................. 9

E. FLEX ALERT PROGRAM COST/BENEFIT OVERVIEW ................................................... 9F. FLEX ALERT PROGRAM TRANSFER PROPOSAL AND RECOMMENDATIONS ................. 10

1. CAISO Is Willing To Administer the Flex Alert Program .................................................................. 102. Utilities’ Recommendations .................................................................................................................. 113. Utilities Will Continue Local Demand Response Notifications ........................................................12

G. EXPLORATION OF ALTERNATIVE ENTITIES............................................................... 12H. FLEX ALERT BRAND ............................................................................................. 13APPENDIX A ............................................................................................................. 15

1. What Is A Flex Alert?............................................................................................................................. 15

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A. Executive Summary

In Decision (D.) 12-05-015, the Commission directed the Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and Southern California Gas Company (collectively, the Utilities) and California Independent System Operator (CAISO) to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015.

Through discussions and analysis in the development of this transfer proposal, the Utilities agree that the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity would not be necessary if certain recommendations were implemented. The Utilities recommend the following:

The Commission should discontinue and eliminate funding for paid media for the Flex Alert program;

CAISO should request Walter McGuire & Company to transfer the Flex Alert trademark and the Flex Alert Network to CAISO;

CAISO should request Walter McGuire & Company to transfer the FlexAlert.org URL and redirect traffic to CAISO’s website;

CAISO should include dedicated Flex Alert web content as part of the CAISO website;

CAISO should continue its non-paid Flex Alert activities such as CAISO news bulletins, notifications to subscribers, and social media messaging;

The Utilities should include Flex Alert messaging as part of their local demand response marketing, education, and outreach (ME&O); and

Statewide ME&O should support generating awareness on Flex Alert.

Once the above recommendations are implemented, utility funding and administration of the Flex Alert program will not be necessary.

B. Background

On May 10, 2012, the Commission adopted Decision (D.) 12-05-015, which provided guidance on the 2013-2014 energy efficiency portfolios and 2012 marketing, education, and outreach activities. Ordering Paragraph 117 of D.12-05-015 required the Utilities to file applications for statewide ME&O activities for demand-side management (DSM) programs.

On August 3, 2012, the Utilities filed their applications seeking approval of statewide ME&O activities for demand-side management programs in 2013-2014. On

2

November 8, 2012, Administrative Law Judge (ALJ) Fitch consolidated the Utilities’ applications into a single proceeding (A.12-08-007 et al).

On January 18, 2013, Assigned Commissioner Ferron and ALJ Roscow issued a ruling dividing A.12-08-007 et al into two phases. Phase 1 would address budgets for the Flex Alert program for 2013-2014; and Phase 2 would address all other aspects of the statewide ME&O plans for 2013-2014. On April 26, 2013, the Commission issued D.13-04-021 establishing the Utilities’ annual budgets for the Flex Alert program for 2013-2014. D.13-04-021 contained the following ordering paragraphs:

Ordering Paragraph (OP) 17 of D.13-04-021 required that the Utilities and CAISO file and serve in A.12-08-007 et al., by May 17, 2013, a jointly prepared report which details how the Utilities and ISO coordinate messaging during Flex Alert events today, and how they will optimize these efforts beginning summer 2013. This report was filed and served on May 17, 2013.1

OP 14 of D.13-04-021 required that SCE take the lead in initiating and coordinating an Evaluation, Measurement and Verification (EM&V) study of Flex Alert, measuring 2013 ex post load impacts. SCE was required to file and serve the proposal in this proceeding no later than January 31, 2014. A portion of the 2012-2014 EM&V budgets authorized in Decision 12-04-045 was allocated to fund this study. On January 28, 2014, SCE requested an extension of time to comply with OP 14, and filed and served the study on February 28, 2014.2

OP 16 of D.13.04.021 required that the Utilities, CAISO, and other interested parties to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015. In compliance OP 16, this Proposal outlining the transfer of the Flex Alert program is flied and served on March 31, 2014.

C. Summary of Parties’ Positions on Flex Alert Program

1. SDG&E Highlights the Need for an EM&V Study

In SDG&E Application (A.) 12-12-016 “Appendix X – SDG&E Response to Energy Division Guidance for Post Summer 2012 DR Evaluation and 2013/2014 Summer Planning,” SDG&E highlighted the need for a comprehensive EM&V study of the Flex Alert program to determine the level of customer understanding of the differences between Flex Alert and local demand response programs, and an evaluation

1 http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M076/K841/76841409.PDF 2 http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M088/K944/88944461.PDF

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of the load impacts of the program. This proposal was widely supported by the Utilities.In D.13-04-021, the Commission approved the load impact study (OP 14) and stated “it is reasonable that, given the continued reliance upon Flex Alerts for urgent conservation and load reduction, the actual success of the program should be analyzed in order to support future decisions on whether to increase funding and expand the program.”3


SDG&E agreed with SCE’s proposal4 to transfer the administration and funding responsibilities of Flex Alert to CAISO in 2015. Since CAISO is the only entity that can issue a Flex Alert, and the main purpose for issuing a Flex Alert is for statewide grid reliability5, funding for this type of program should be borne by all ratepayers in the state, rather than solely Utility ratepayers. Since CAISO has load management control over investor-owned and several municipal electric utilities, CAISO may be better suited in securing funding from a broader base of ratepayers benefitting from the program.

CAISO supported the general notion of exploring different funding and administration options for the Flex Alert program but argued that the EM&V study should inform the proposal. CAISO also recommended exploring transferring responsibilities to another entity (such as the California Energy Commission), to address concerns about the viability of available funding mechanisms.6

In D.13-04-021, the Commission found merit in the transfer proposal and stated that “it is logical that the entity controlling the program, ISO, also be responsible for administering and securing funding for the program, and that the funding is provided by all customers who benefit from the conservation and load reduction due to Flex Alerts, not just the ratepayers of the investor-owned utilities.”7 The Commission directed SCE to work with PG&E, SDG&E, CAISO, and other interested parties to develop a transfer proposal.8

D. Flex Alert Research Findings

Several Flex Alert research studies covering process and load impact analyses have been conducted in recent program cycles.9 These studies are summarized below and used to inform the Utilities’ joint recommendation to transfer the Flex Alert program to CAISO.

3 D.13-04-021, p. 21. 4 A.12-08-008, p. 25, lines 5-7 5 Flex Alerts can be called separately for Northern and Southern California 6 CAISO’s Comments on Proposed Decision Phase 1, p.3 7 D.13-04-021, p.22 8 D.13-04-021, OP 16. 9 Studies are available at www.calmac.org.

4



Summary: Most people understand the requested conservation actions, and end up conserving electricity, but confuse the need for conservation actions on particular days, not just particular times of day.10 Inconsistent and frequently changing program names and logos contribute to the confusion and weaken the message.11

Customers see the state and utilities as the appropriate leaders of this effort and news anchors as the most compelling source of information if an event is called.12 The load impact analysis was inconclusive and Flex Alert’s contribution to the estimated 200-1100 MW system response on Flex Alert days was unclear.13


Description: This report evaluated whether recommendations from the 2006-2007 Flex Your Power NOW! Evaluation Report were implemented, evaluated the effectiveness of the campaign in increasing customer awareness, assessed what conservation actions were taken and when, and determined key barriers to program participation.

Summary: Messaging consistency notably improved since it was first tested in the 2006-2007 Flex Your Power NOW! Evaluation Report. Overall, 67% of respondents recalled some sort of energy conservation message or the Flex Alert (unaided and aided recall combined) and had a good recall of the requested conservation actions.14

However, very few respondents understood that conservation was especially needed on particular days.15 Significant media coverage of Flex Alerts occurred in the beginning of an event, but if an event lasted more than two days, media coverage declined considerably.16 Paid advertising communicated essential details about Flex Alerts more clearly than news media coverage.17 The load impact estimate for the 2008 Flex Alert campaign was approximately 222 to 282 MW based on self-reported air conditioner and lighting behaviors. These impacts are not verified as they were based on self-reporting, without an analysis of actual energy usage.18 Furthermore, this study revisited

10 2006-2007 Flex Your Power NOW! Evaluation Report, p.4 11 2006-2007 Flex Your Power NOW! Evaluation Report, p.3 12 2006-2007 Flex Your Power NOW! Evaluation Report, p.6 and p.53 13 2006-2007 Flex Your Power NOW! Evaluation Report, p.5 14 2008 Flex Alert Campaign Evaluation Report, p.7 15 2008 Flex Alert Campaign Evaluation Report, p.7 16 2008 Flex Alert Campaign Evaluation Report, p.3 17 2008 Flex Alert Campaign Evaluation Report, p.7 18 2008 Flex Alert Campaign Evaluation Report, p.9

5

assumptions made in the 2006-2007 load impact estimate by using more detail on timing of actions, setpoints, and building characteristics, resulting in a revision downwards from 93-495 MW to 45-75 MW.19


Description: This study evaluated 2012 load impacts of SCE’s and SDG&E’s peak time rebate (PTR) programs and the effect of the two Flex Alert events called in 2012. SDG&E called seven PTR events in 2012, two of which occurred on the two Flex Alert days of August 10 and August 14. SCE called six PTR events, one of which was on the same day as the August 10 Flex Alert day. SDG&E included both notified and non-notified residential and small business customers, while SCE only included notified residential customers in the study.




Summary:22 In 2013, there were 3 Flex Alert event days (April 16, July 1, and July 2), all of which were localized within PG&E’s service territory. The study found that no statistically significant load reductions could be attributed to the occurrence of Flex Alert event days. Both of the July Flex Alert event days coincided with event days for nearly every PG&E demand response program, which limited the ability to isolate any load reductions due to Flex Alert from the load reductions caused by the demand response programs.

The April 16 Flex Alert event was unusual due to the cause (vandalism severely damaged transformers at a substation in the San Jose area rather than a weather-related event), the event was called at approximately midnight instead of the typical daytime period, and the event also activated a wide variety of PG&E’s demand response programs. The April Flex Alert day applied to areas outside of PG&E’s

19 2008 Flex Alert Campaign Evaluation Report, p.9 20 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.15 21 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.16 22 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.1

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service territory, but data is only available for PG&E’s entire service area rather than the specific area affected.




Paid advertising ran from June 10 through September 29, 2013, and focused primarily on the Southern California region. Television advertisements aired exclusively in Southern California as did all advertising in languages other than English. The Northern region’s broadcast media tactics only included spot and traffic radio. Between April 16 and September 24, 2013, there were 297 news items which mentioned Flex Alerts.26 A large majority of Flex Alert earned media coverage (85%) appeared in Northern California, where all of the 2013 Flex Alert events took place.27

Flex Alert events on April 16, 2013 and February 7, 2014 occurred during mild weather with origins unrelated to extreme heat. The two events called in anticipation of extreme heat (July 1 and 2, 2013) focused on constraints in Northern California. The variability in each of these events could therefore reduce the effectiveness of pre-planned marketing campaigns. In other words, a canned message to reduce energy

23 At the time of this filing of the Flex Alert Transfer Proposal, the 2013 Flex Alert Process Evaluation study has not been finalized and, therefore, should be considered preliminary in its findings. The study is currently in review by the Demand Response Measurement and Evaluation Committee (DRMEC) which includes members from SCE, SDG&E, PG&E, Energy Division and the CEC. Please use the following instructions to access the draft reports on the website:

Go to www.sce.com/applications; Under “CPUC Open Proceedings,” type A.12-08-007 into the search box; Click “GO;” From the Search Results screen, click the icon in the “Attachment” column that corresponds to

the document you want to view; The document is presented in a PDF format (.pdf) and can be viewed online, printed, or saved to

your hard drive. 24 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V25 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V 26 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76 27 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.78

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usage from 1-6 pm is not effective when the event is called during other hours. During 2013, earned media provided responsive and credible coverage of Flex Alerts. Pre-scheduling media purchasing reflects a level of predictability that may not reflect grid conditions.28

Over the summer, the Flex Alert program’s paid media generated a much larger number of impressions than the program gained from earned media (see Table 1). However, during the days surrounding events, earned media generated far more impressions than paid broadcast media. During the July event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place.29

Table 1: Impressions30 per Day from Earned Media and Paid Media

OUTREACH TYPE

2013 DEMAND RESPONSE SEASON

(JUN 10-SEP 22)

APRIL 2013EVENT PERIOD

(APR 16-APR 17)

JULY 2013EVENT PERIOD (JUN 30-JUL 3)

FEBRUARY 2014EVENT PERIOD (FEB 6-FEB 7)

NORTHERN CALIFORNIA

Paid Media 1,465,529 - 832,593 -

Earned Media 269,938 1,525,768 6,772,823 5,482,235

SOUTHERN CALIFORNIA

Paid Media 5,947,297 - 4,195,933 -

Earned Media 21,150 217,345 358,081 4,041,004

In general, the most frequently reported source of Flex Alert awareness was television.31 Interviews with media professionals confirmed that the reporters and editors responsible for covering Flex Alerts view the events as newsworthy, primarily due to the implied potential for energy shortages to result in power outages.32 The statewide program stakeholders noted that Flex Alerts garner significant media attention. However, staff and stakeholders had differing levels of certainty around the value of the paid media campaign – while some were convinced it was necessary to keep the public aware of the brand and informed about what to do during an event, others believe the earned media might be sufficient.33


28 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV 29 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV 30 Impressions are defined as views 31 Process Evaluation of the 2013 Statewide Flex Alert Program, p.32 32 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 33 Process Evaluation of the 2013 Statewide Flex Alert Program, p.VI 34 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV

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On February 6, 2014, CAISO called a statewide Flex Alert event due to several gas-fired power plants that were curtailed because of natural gas shortages. An analysis of Flex Alert media coverage in Southern, Central, and Northern California media markets conducted by SCE shortly thereafter showed that 79 media outlets that carried the story on either February 6 or February 7, provided approximately nine million impressions. This report confirms findings from previous studies that earned media during events effectively generates impressions. More importantly, there was no paid advertising in market at the time of the February 6 event and was a good outcome because the Flex Alert hours were not consistent with what would have been in market.Details of the analysis:










Radio 3 29 702,100Total 21 66 4,972,665


RadioTotal 58 111 3,810,782

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For TV and radio, the average quarter hour audience numbers for the time period when the spot ran were used to calculate the number of impressions. For digital, the average monthly visitors, divided by 30 days and then multiplied by 25% to account for the fact that not all visitors would have seen the story, was used as the calculation. The analysis did not identify any newspapers that carried the story in their print editions for the Southern California media market.



News anchors are seen as the most compelling source of information if an event is called but paid advertising communicated essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. During the July 2013 event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately five million impressions even without any paid advertising in market at the time of this particular event.

Over the last several months, the use of Flex Alerts has been unpredictable which reduces the effectiveness of pre-planned marketing campaigns. There were two Flex Alert events that occurred during mild weather with origins unrelated to extreme heat (April 16, 2013 and February 6, 2014) and two additional events (July 1 and 2, 2013) occurring in anticipation of extreme heat focused on constraints in Northern California.

Several studies attempted to measure Flex Alert load impacts, but all have been inconclusive in their findings. SCE’s and SDG&E’s joint 2012 load impact study35

concluded that load increased on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR-only event days.

E. Flex Alert Program Cost/Benefit Overview

The table below outlines the total annual authorized budget, paid media expenditures, fixed administrative costs, agency costs, the number of Flex Alert events,


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and load impact (if available) per program year since 2006. The Flex Alert program budget from 2006 to 2013 totals $62 million, with 35 events called during this time frame and no conclusive load impacts.

ProgramYear

Annual AuthorizedBudget (total


Paid Media Costs (total

media spend for all IOUs

combined)

Fixed Admin Costs (website, outreach/network,

production)

Agency Costs (media


Number of Flex Alert

Events37

LoadImpact


MWs)38

2006 $ 6,649,247

Data not provided39

18 45 - 75 2007 $ 6,650,076 6 2008 $ 6,650,896 3 222 - 282 2009 $ 5,477,273 0 n/a2010 $ 4,200,292 0 n/a2011 $ 2,929,311 $2,584,945 $ 97,000 $ 311,004 2 n/a2012 $10,000,000 $7,788,166 $715,216 $1,024,633 2 n/a2013 $10,000,000 $8,452,607 $133,000 $1,014,313 3 0 2014 $10,000,000 n/a n/a n/a 1 0

TOTAL $62,557,095 n/a n/a n/a 35 n/a

F. Flex Alert Program Transfer Proposal and Recommendations

1. CAISO Is Willing To Administer the Flex Alert Program

CAISO has the scope of knowledge relative to balancing area resources ability to evaluate and balance resources within its authority area and can initiate a Flex Alert specifically for that area. The CAISO has generation load balancing control over both investor-owned and several municipal electric utilities for the CAISO balancing area, and the Utilities in that area have limited control over the. However, the CAISO balancing area does not cover all of California. Substantial portions are controlled by other load serving entities and the intent for a statewide program would not be satisfied by a CAISO-only program. Other balancing areas in California have similar knowledge for their respective areas, but they do not currently participate in the Flex Alert program (although they may benefit from spillover Flex Alert messaging). A statewide program was cited as desirable. Nonetheless, CAISO has expressed willingness and is an appropriate entity to administer the Flex Alert program, contingent on the CAISO’s ability to use the Flex Alert brand, and the understanding that the program would be triggered in response to needs of the CAISO balancing area only.

36 Authorized Budgets 2006-2008: D.06-03-024, OP 1. Authorized Budgets 2009-2011: D.09-08-027, OP 17. Authorized Budget 2012: D.12-04-045, OP 19. Authorized Budgets 2013-2014: D.13-04-021, OP 1, OP 2, OP 3. 37 Source: http://www.caiso.com/Documents/Alert_WarningandEmergenciesRecord.pdf38 2006-2007 load impact results revised results shown in table as identified in the 2008 Flex Alert Campaign Evaluation Report. 2008 results based on self-reported air-conditioner and lighting behaviors, not verified. 2013 impact study found no statistically significant load reductions attributable to Flex Alert event days. 39 PG&E statewide lead for the Flex Alert program in 2006-2010.

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2. Utilities’ Recommendations

Utility funding and administration of the Flex Alert program will not be necessary if the following recommendations were implemented:

The Commission should discontinue and eliminate funding for paid media the Flex Alert program. Research found that unpaid media has effectively generated consumer engagement through public service announcements or news media reports.40 Unpaid media is seen as the most compelling and reliable source of information when a Flex Alert event is called. The value of paid media has been disputed by several stakeholders and has not provided quantifiable load impacts. Eliminating the paid statewide campaign is a reasonable approach;

CAISO should request Walter McGuire & Company to transfer the Flex Alert trademark and the Flex Alert Network to CAISO. CAISO should manage the Flex Alert Network, which supports the overall communication strategy, as almost all organizations that participated in the Flex Alert Email Survey41 reported that an event causes them to take action;

CAISO should request Walter McGuire & Company to transfer the FlexAlert.org URL, redirect traffic to CAISO’s website and discontinue the current Flex Alert website;

CAISO should include dedicated Flex Alert web content as part of the CAISO website www.caiso.com;

CAISO should continue its non-paid Flex Alert activities such as CAISO notifications to subscribers via the CAISO website or its smart phone application, Twitter, Google+ and Facebook social media as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013”. In addition, CAISO should coordinate with state agencies to include the Flex Alert logo on government websites. The Flex Alert logo should be switched from green to red during a Flex Alert event;

The Utilities should integrate Flex Alert messaging as part of their local demand response ME&O. With the discontinuance of paid media for statewide Flex Alert activities, the Utilities will integrate Flex Alert messaging into their local demand response ME&O activities to maintain awareness of the program and support CAISO’s unpaid activities.Examples include SCE’s Summer Readiness residential brochure which includes an explanation of the difference between Save Power Day and Flex Alert, and SCE’s Summer Readiness non-residential flyer with energy

40 2013 Process Evaluation of the 2013 Statewide Flex Alert Program. February 6, 2014 Flex Alert Media Report 41 2013 Process Evaluation of the 2013 Statewide Flex Alert Program

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saving tips and Flex Alert educational messaging. In addition, the Utilities’ Corporate Communication organizations will facilitate media coverage when a Flex Alert is issued. This integration significantly reduces the ratepayer funding needed and creates an effective opportunity to explain the differences between Flex Alerts and local demand response notifications. Integrating Flex Alert messaging with Utility-managed demand response general awareness activities can also be supported by the statewide demand response ME&O budgets, which were approved in D.13-12-038.; and

Statewide ME&O should support generating awareness on Flex Alert. The goal of the Statewide Marketing, Education and Outreach Campaign (Energy Upgrade California), managed by the California Center for Sustainable Energy (CCSE) for the 2014-2015 program cycle, is that “Californians understand the value of energy efficiency, demand response, and distributed generation which leads to demand for products, services and rates for their homes and businesses.” Since generating awareness and understanding of demand response is part of the scope for this campaign, tactics such as paid media, earned/social media, website content, CBO outreach/education, and event outreach include general education about demand response and Flex Alerts. CCSE has also expressed their support for promoting Flex Alert event days in the “hero box” on the statewide Energy Upgrade California website and via social media channels.

Implementation of these recommendations would transfer and streamline responsibilities and activities to the appropriate organizations pertaining to the Flex Alert program.


The Utilities will continue with local demand response program notifications to engage participation and achieve load reductions. In addition, given sufficient advance notice, the Utilities could dispatch certain programs and change website content when a Flex Alert is issued.

G. Exploration of Alternative Entities

The Utilities considered the California Energy Commission (CEC) as an alternative entity to administer and fund the Flex Alert program in preparing this transfer proposal. However, after a preliminary review, the Utilities concluded that a transfer to the CEC would mean exploring an unknown and potentially complex funding structure that may take a lengthy time to construct, adding an additional entity that would need to coordinate with CAISO (the only entity that can initiate a Flex Alert in its balancing area), and determining whether CEC is willing or able to take over the responsibilities for this statewide program. Because CAISO expressed support for accepting

13

administration of the Flex Alert program and they were the only party who recommended exploring additional entities, the Utilities did not engage in discussions with the CEC.

A second alternative entity considered was the California Utilities Emergency Association (CUEA). CUEA serves as a point-of-contact for critical infrastructure utilities and the California Office of Emergency Services (Cal OES) and other Governmental Agencies before, during and after an event to:42




CUEA was recently brought to the Utilities’ attention as an option for taking on the statewide responsibility for the Flex Alert program and was approached in the final stage of preparing this transfer proposal. Due to the limited opportunity for CUEA to provide input, the Utilities have not received their feedback and it is not incorporated herein.

H. Flex Alert Brand

The Flex Alert brand is owned by Walter McGuire & Company, Inc. (McGuire) as of November 9, 2010.43 Continuing with this brand name, therefore, would require approval from McGuire as neither CAISO nor the Commission owns the trademark.

Research has shown44 that inconsistent and infrequently changing program names and logos are confusing and weaken the message. The Utilities recommended that CAISO explore obtaining the required approvals to continue with the Flex Alert brand.

SCE facilitated a meeting on March 17, 2014, between CAISO and McGuire in which the following topics were covered regarding the Flex Alert brand:

42 Source: www.cueainc.com 43 United States Patent and Trademark Office: Registration Number 3872849 44 2006-2007 Flex Your Power NOW! Evaluation Report

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CAISO and McGuire agreed that a contract would be required if this activity is to continue in its current form in 2015.


each member by phone to ensure accuracy of contact information. Network members are alerted through e-blasts distributed by McGuire.

Transferring the e-blast responsibilities to another entity, such as the CAISO, would require a review of the agreements McGuire holds with the Network members to determine if this would be allowed.

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APPENDIX A




Exhibit 4

1

Andrea Tozer

From: Roland MollenSent: Friday, July 31, 2015 10:59 AMTo: Andrea TozerSubject: FW: Final review: Flex Alert Transfer ProposalAttachments: Flex Alert Transfer Proposal - FINAL DRAFT.docx

And the 3/31 email. Yay!

Roland MollenProject ManagerDSM Policy & ComplianceSouthern California EdisonDesk: (626) 302 0855 PAX 20855Cell: (909) 471 0918


From: Roland Mollen [mailto:[email protected]]Sent:Monday, June 15, 2015 7:25 AMTo: David LowreyCc: Roland MollenSubject: Fw: Final review: Flex Alert Transfer Proposal

3/31 email with attachment



From: Roland Mollen/SCE/EIXTo: "McKenna, Anna" <[email protected]>, "Yip, Andrew" <[email protected]>, [email protected], "Van Pelt, Gregory" <[email protected]>, [email protected], "Long, Lisa" <[email protected]>, "Agustin, Melody" <[email protected]>, [email protected],Cc: Aimee Wong/SCE/EIX@SCE, Andrea Tozer/SCE/EIX@SCE, Brian Kopec/SCE/EIX@SCE, David Lowrey/SCE/EIX@SCE, Michelle Thomas/SCE/EIX, Nancy Jenkins/SCE/EIX@SCE, Don Arambula/SCE/EIX@SCEDate: 03/31/2014 08:36 PMSubject: Final review: Flex Alert Transfer Proposal


All,

2

The Commission was closed today due to the Cesar Chavez holiday and this provided us with some extra time to incorporate all the edits we've received from the stakeholders to this proposal. Attached you'll find the final draft, with edits in tracked changes. Kind request to take one last look and send me your final thoughts and/or approval by 11:00 tomorrow. We'll file the report in the afternoon.

(See attached file: Flex Alert Transfer Proposal - FINAL DRAFT.docx)

Many thanks to all of you for your contributions!




Roland Mollen---03/28/2014 04:51:06 PM---All, Thanks for your patience! It took a bit longer than expected unfortunately to edit the proposal

From: Roland Mollen/SCE/EIXTo: "Yip, Andrew" <[email protected]>, "Long, Lisa" <[email protected]>, "Agustin, Melody" <[email protected]>, [email protected],[email protected], [email protected], "McKenna, Anna" <[email protected]>, "Van Pelt, Gregory" <[email protected]>,Cc: Andrea Tozer/SCE/EIX@SCE, David Lowrey/SCE/EIX@SCE, Aimee Wong/SCE/EIX@SCE, Michelle Thomas/SCE/EIX, Brian Kopec/SCE/EIX@SCEDate: 03/28/2014 04:51 PMSubject: Final review: Flex Alert Transfer Proposal


All,



[attachment "Flex Alert Transfer Proposal - V12.docx" deleted by Roland Mollen/SCE/EIX]

3






Table of Contents

A. EXECUTIVE SUMMARY ............................................................................................. 1B. BACKGROUND ...................................................................................................... 21C. SUMMARY OF PARTIES’ POSITIONS ON FLEX ALERT PROGRAM .................................. 3

1. SDG&E Highlights the Need for an EM&V Study ............................................................................... 32. SDG&E Proposed Transferring the Flex Alert Program to CAISO ...................................................3

D. FLEX ALERT RESEARCH FINDINGS ........................................................................... 41. 2006-2007 Flex Your Power NOW! Evaluation Report ...................................................................... 42. 2008 Flex Alert Campaign Evaluation Report ..................................................................................... 43. Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and

SDG&E’s Peak Time Rebate Programs .............................................................................................. 54. 2013 Impact Evaluation of California’s Flex Alert Demand Response Program ..........................655. 2013 Process Evaluation of the 2013 Statewide Flex Alert Program ..............................................66. February 6, 2014 Flex Alert Event Media Report................................................................................ 87. Overall Flex Alert Research Studies Conclusions .............................................................................. 9

E. FLEX ALERT PROGRAM COST/BENEFIT OVERVIEW ................................................. 10F. FLEX ALERT PROGRAM TRANSFER PROPOSAL AND RECOMMENDATIONS ............. 1110

1. CAISO Is Willing To Administer the Flex Alert Program ..............................................................11102. Utilities’ Recommendations .................................................................................................................. 113. Utilities Will Continue Local Demand Response Notifications ....................................................1312

G. EXPLORATION OF ALTERNATIVE ENTITIES............................................................... 13H. FLEX ALERT BRAND ............................................................................................. 14APPENDIX A ......................................................................................................... 1716

1. What Is A Flex Alert?......................................................................................................................... 1716

1

A. Executive Summary

In Decision (D.) 12-05-015, D.13-04-021, the Commission directed the PacificGas and Electric Company (PG&E), Southern California Edison Company (SCE), San Diego Gas & Electric Company (SDG&E), and Southern California Gas Company (collectively, the Utilities), and California Independent System Operator (CAISO) to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015.

Through discussions and analysis in the development of this transfer proposal, the Utilities agree that the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity would not be necessary if certain recommendations were implemented. Through discussions and analysis in the development of this proposal, the Utilities agree that discontinuation of Utility funding of Flex Alert is appropriate at this time. The Utilities also agree that CAISO can continue to operate the Flex Alert program as follows:The Utilities recommend the following:

The Commission should discontinue and eliminateUtility funding for paid media for the Flex Alert program;

CAISO should request that Walter McGuire & Company to transfer the Flex Alert trademark and the Flex Alert Network to CAISO;

CAISO should request that Walter McGuire & Company to transfer the FlexAlert.org URL and redirect traffic to CAISO’s website;

CAISO should include dedicated Flex Alert web content as part of the CAISO website;

CAISO should continue its non-unpaid Flex Alert activities, such as CAISO news bulletins, notifications to subscribers, and social media messaging;

The Utilities should can include Flex Alert messaging as part of their local demand responsegeneral awareness outreach through marketing, education, and outreach (ME&O) activities; and

Statewide ME&O should support generating awareness on of Flex Alert.

Once If the above recommendations are implemented this year, utility Utility funding and administration of the Flex Alert program will not be necessary in 2015.

CAISO has expressed its willingness to continue conducting the Flex Alert program functions it currently executes and undertake additional responsibilities specifically for their balancing area only. However, CAISO is concerned over the lack of a funding mechanism proposal to cover administrative costs associated with undertaking these additional responsibilities, which would include the transfer of the Flex Alert trademark, managing the Flex Alert Network, and coordination of websites maintaining Flex Alert content.

2

The Utilities are supportive of CAISO continuing the Flex Alert program and undertaking the additional responsibilities outlined above but recommend for CAISO to find a funding solution for the administrative costs associated with these activities.

B. Background

On May 10, 2012, the Commission adopted Decision (D.) 12-05-015, which provided guidance on the 2013-2014 energy efficiency portfolios and 2012 marketing, education, and outreach activities. Ordering Paragraph 117 of D.12-05-015 required the Utilities to file applications for statewide ME&O activities for demand-side management (DSM) programs.


On January 18, 2013, Assigned Commissioner Ferron and ALJ Roscow issued a ruling dividing A.12-08-007 et al into two phases. Phase 1 would address budgets for the Flex Alert program for 2013-2014; and Phase 2 would address all other aspects of the statewide ME&O plans for 2013-2014. On April 26, 2013, the Commission issued D.13-04-021 establishing the Utilities’ annual budgets for the Flex Alert program for 2013-2014. D.13-04-021 contained the following ordering paragraphs:

Ordering Paragraph (OP) 17 of D.13-04-021 required that the Utilities and CAISO file and serve in A.12-08-007 et al., by May 17, 2013, a jointly prepared report which details how the Utilities and ISO coordinate messaging during Flex Alert events today, and how they will optimize these efforts beginning summer 2013. This report was filed and served on May 17, 2013.1

OP 14 of D.13-04-021 required that SCE take the lead in initiating and coordinating an Evaluation, Measurement and Verification (EM&V) study of Flex Alert, measuring 2013 ex post load impacts. SCE was required to file and serve the proposal in this proceeding no later than January 31, 2014. A portion of the 2012-2014 EM&V budgets authorized in Decision 12-04-045 was allocated to fund this study. On January 28, 2014, SCE requested an extension of time to comply with OP 14, and filed and served the study on February 28, 2014.2

1 http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M076/K841/76841409.PDF 2 http://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M088/K944/88944461.PDF

3

OP 16 of D.13.04.021 required that the Utilities, CAISO, and other interested parties to work together to develop a proposal for the transfer of the administration and funding of the Flex Alert program to the CAISO or another entity, effective in 2015. In compliance OP 16, this Proposal outlining the transfer of the Flex Alert program is flied and served on March 31, 2014.

C. Summary of Parties’ Positions on Flex Alert Program

1. SDG&E Highlights the Need for an EM&V Study

In SDG&E Application (A.) 12-12-016 “Appendix X – SDG&E Response to Energy Division Guidance for Post Summer 2012 DR Evaluation and 2013/2014 Summer Planning,” SDG&E highlighted the need for a comprehensive EM&V study of the Flex Alert program to determine the level of customer understanding of the differences between Flex Alert and local demand response programs, and an evaluation of the load impacts of the program. This proposal was widely supported by the Utilities.In D.13-04-021, the Commission approved the load impact study (OP 14) and stated “it is reasonable that, given the continued reliance upon Flex Alerts for urgent conservation and load reduction, the actual success of the program should be analyzed in order to support future decisions on whether to increase funding and expand the program.”3


SDG&E agreed with SCE’s proposal4 to transfer the administration and funding responsibilities of Flex Alert to CAISO in 2015. Since CAISO is the only entity that can issue a Flex Alert, and the main purpose for issuing a Flex Alert is for statewide grid reliability5, funding for this type of program should be borne by all ratepayers in the state, rather than solely Utility ratepayers. Since CAISO has load management control over investor-owned and several municipal electric utilities, CAISO may be better suited in securing funding from a broader base of ratepayers benefitting from the program.

CAISO supported the general notion of exploring different funding and administration options for the Flex Alert program but argued that the EM&V study should inform the proposal. CAISO also recommended exploring transferring responsibilities to another entity (such as the California Energy Commission), to address concerns about the viability of available funding mechanisms.6

In D.13-04-021, the Commission found merit in the transfer proposal and stated that “it is logical that the entity controlling the program, ISO, also be responsible for administering and securing funding for the program, and that the funding is provided by

3 D.13-04-021, p. 21. 4 A.12-08-008, p. 25, lines 5-7 5 Flex Alerts can be called separately for Northern and Southern California 6 CAISO’s Comments on Proposed Decision Phase 1, p.3

4

all customers who benefit from the conservation and load reduction due to Flex Alerts, not just the ratepayers of the investor-owned utilities.”7 The Commission directed SCE to work with PG&E, SDG&E, CAISO, and other interested parties to develop a transfer proposal.8

D. Flex Alert Research Findings

Several Flex Alert research studies covering process and load impact analyses have been conducted in recent program cycles.9 These studies are summarized below and used to inform the Utilities’ joint recommendation. to transfer the Flex Alert program to CAISO.



Summary: Most people understand the requested conservation actions, and end up conserving electricity, but confuse the need for conservation actions on particular days, not just particular times of day.10 Inconsistent and frequently changing program names and logos contribute to the confusion and weaken the message.11

Customers see the state and utilities as the appropriate leaders of this effort and news anchors as the most compelling source of information if an event is called.12 The load impact analysis was inconclusive and Flex Alert’s contribution to the estimated 200-1100 MW system response on Flex Alert days was unclear.13


Description: This report evaluated whether recommendations from the 2006-2007 Flex Your Power NOW! Evaluation Report were implemented, evaluated the effectiveness of the campaign in increasing customer awareness, assessed what conservation actions were taken and when, and determined key barriers to program participation.

7 D.13-04-021, p.22 8 D.13-04-021, OP 16. 9 Studies are available at www.calmac.org.10 2006-2007 Flex Your Power NOW! Evaluation Report, p.4 11 2006-2007 Flex Your Power NOW! Evaluation Report, p.3 12 2006-2007 Flex Your Power NOW! Evaluation Report, p.6 and p.53 13 2006-2007 Flex Your Power NOW! Evaluation Report, p.5

5

Summary: Messaging consistency notably improved since it was first tested in the 2006-2007 Flex Your Power NOW! Evaluation Report. Overall, 67% of respondents recalled some sort of energy conservation message or the Flex Alert (unaided and aided recall combined) and had a good recall of the requested conservation actions.14

However, very few respondents understood that conservation was especially needed on particular days.15 Significant media coverage of Flex Alerts occurred in the beginning of an event, but if an event lasted more than two days, media coverage declined considerably.16 Paid advertising communicated essential details about Flex Alerts more clearly than news media coverage.17 The load impact estimate for the 2008 Flex Alert campaign was approximately 222 to 282 MW based on self-reported air conditioner and lighting behaviors. These impacts are not verified as they were based on self-reporting, without an analysis of actual energy usage.18 Furthermore, this study revisited assumptions made in the 2006-2007 load impact estimate by using more detail on timing of actions, setpoints, and building characteristics, resulting in a revision downwards from 93-495 MW to 45-75 MW.19


Description: This study evaluated 2012 load impacts of SCE’s and SDG&E’s peak time rebate (PTR) programs and the effect of the two Flex Alert events called in 2012. SDG&E called seven PTR events in 2012, two of which occurred on the two Flex Alert days of August 10 and August 14. SCE called six PTR events, one of which was on the same day as the August 10 Flex Alert day. SDG&E included both notified and non-notified residential and small business customers, while SCE only included notified residential customers in the study.


14 2008 Flex Alert Campaign Evaluation Report, p.7 15 2008 Flex Alert Campaign Evaluation Report, p.7 16 2008 Flex Alert Campaign Evaluation Report, p.3 17 2008 Flex Alert Campaign Evaluation Report, p.7 18 2008 Flex Alert Campaign Evaluation Report, p.9 19 2008 Flex Alert Campaign Evaluation Report, p.9 20 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.15 21 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.16

6



Summary:22 In 2013, there were 3 Flex Alert event days (April 16, July 1, and July 2), all of which were localized within PG&E’s service territory. The study found that no statistically significant load reductions could be attributed to the occurrence of Flex Alert event days. Both of the July Flex Alert event days coincided with event days for nearly every PG&E demand response program, which limited the ability to isolate any load reductions due to Flex Alert from the load reductions caused by the demand response programs.

The April 16 Flex Alert event was unusual due to the cause (vandalism severely damaged transformers at a substation in the San Jose area rather than a weather-related event), the event was called at approximately midnight instead of the typical daytime period, and the event also activated a wide variety of PG&E’s demand response programs. The April Flex Alert day applied to areas outside of PG&E’s service territory, but data is only available for PG&E’s entire service area rather than the specific area affected.



Summary: There are relatively high levels of familiarity with the term “Flex Alert” and understanding of the requested conservation actions.24 However, there is likely still

22 2013 Impact Evaluation of California’s Flex Alert Demand Response Program, p.1 23 At the time of this filing of the Flex Alert Transfer Proposal, the 2013 Flex Alert Process Evaluation study has not been finalized and, therefore, should be considered preliminary in its findings. The study is currently in review by the Demand Response Measurement and Evaluation Committee (DRMEC) which includes members from SCE, SDG&E, PG&E, Energy Division and the CEC. Please use the following instructions to access the draft reports on the website:

Go to www.sce.com/applications; Under “CPUC Open Proceedings,” type A.12-08-007 into the search box; Click “GO;” From the Search Results screen, click the icon in the “Attachment” column that corresponds to

the document you want to view; The document is presented in a PDF format (.pdf) and can be viewed online, printed, or saved to

your hard drive.

7

confusion between Flex Alert messaging and utility-based demand response notifications.25

Paid advertising ran from June 10 through September 29, 2013, and focused primarily on the Southern California region. Television advertisements aired exclusively in Southern California as did all advertising in languages other than English. The Northern region’s broadcast media tactics only included spot and traffic radio. Between April 16 and September 24, 2013, there were 297 news items which mentioned Flex Alerts.26 A large majority of Flex Alert earned media coverage (85%) appeared in Northern California, where all of the 2013 Flex Alert events took place.27

Flex Alert events on April 16, 2013 and February 7, 2014 occurred during mild weather with origins unrelated to extreme heat. The two events called in anticipation of extreme heat (July 1 and 2, 2013) focused on constraints in Northern California. The variability in each of these events could therefore reduce the effectiveness of pre-planned marketing campaigns. In other words, a canned message to reduce energy usage from 1-6 pm is not effective when the event is called during other hours. During 2013, earned media provided responsive and credible coverage of Flex Alerts. Pre-scheduling media purchasing reflects a level of predictability that may not reflect grid conditions.28

Over the summer, the Flex Alert program’s paid media generated a much larger number of impressions than the program gained from earned media (see Table 1). However, during the days surrounding events, earned media generated far more impressions than paid broadcast media. During the July event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place.29

Table 1: Impressions30 per Day from Earned Media and Paid Media

OUTREACH TYPE

2013 DEMAND RESPONSE SEASON

(JUN 10-SEP 22)

APRIL 2013EVENT PERIOD

(APR 16-APR 17)

JULY 2013EVENT PERIOD (JUN 30-JUL 3)

FEBRUARY 2014EVENT PERIOD (FEB 6-FEB 7)

NORTHERN CALIFORNIA

Paid Media 1,465,529 - 832,593 -

Earned Media 269,938 1,525,768 6,772,823 5,482,235

24 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V25 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.V 26 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.76 27 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.78 28 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV 29 2013 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV 30 Impressions are defined as views

8

SOUTHERN CALIFORNIA

Paid Media 5,947,297 - 4,195,933 -

Earned Media 21,150 217,345 358,081 4,041,004

In general, the most frequently reported source of Flex Alert awareness was television.31 Interviews with media professionals confirmed that the reporters and editors responsible for covering Flex Alerts view the events as newsworthy, primarily due to the implied potential for energy shortages to result in power outages.32 The statewide program stakeholders noted that Flex Alerts garner significant media attention. However, staff and stakeholders had differing levels of certainty around the value of the paid media campaign – while some were convinced it was necessary to keep the public aware of the brand and informed about what to do during an event, others believe the earned media might be sufficient.33



On February 6, 2014, CAISO called a statewide Flex Alert event due to several gas-fired power plants that were curtailed because of natural gas shortages. An analysis of Flex Alert media coverage in Southern, Central, and Northern California media markets conducted by SCE shortly thereafter showed that 79 media outlets that carried the story on either February 6 or February 7, provided approximately nine million impressions. This report confirms findings from previous studies that earned media during events effectively generates impressions. More importantly, there was no paid advertising in market at the time of the February 6 event and was a good outcome because the Flex Alert hours were not consistent with what would have been in market.Details of the analysis:





31 Process Evaluation of the 2013 Statewide Flex Alert Program, p.32 32 Process Evaluation of the 2013 Statewide Flex Alert Program, p.III 33 Process Evaluation of the 2013 Statewide Flex Alert Program, p.VI 34 Process Evaluation of the 2013 Statewide Flex Alert Program, p.IV

9





For TV and radio, the average quarter hour audience numbers for the time period when the spot ran were used to calculate the number of impressions. For digital, the average monthly visitors, divided by 30 days and then multiplied by 25% to account for the fact that not all visitors would have seen the story, was used as the calculation. The analysis did not identify any newspapers that carried the story in their print editions for the Southern California media market.



News anchors are seen as the most compelling source of information if an event is called but paid advertising communicated essential details about the Flex Alert program more clearly than news media coverage. However, earned media played an important role in providing information about the Flex Alert events on April 16, July 1, and July 2. During the July 2013 event period, earned media provided nearly eight times as many impressions as paid media in Northern California, where the Flex Alert took place. The effectiveness of earned media was confirmed by the media coverage of the February 6, 2014 Flex Alert event, which resulted in approximately five million impressions even without any paid advertising in market at the time of this particular event.


Radio 3 29 702,100Total 21 66 4,972,665


RadioTotal 58 111 3,810,782

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Over the last several months, the use of Flex Alerts has been unpredictable which reduces the effectiveness of pre-planned marketing campaigns. There were two Flex Alert events that occurred during mild weather with origins unrelated to extreme heat (April 16, 2013 and February 6, 2014) and two additional events (July 1 and 2, 2013) occurring in anticipation of extreme heat focused on constraints in Northern California.

Several studies attempted to measure Flex Alert load impacts, but all have been inconclusive in their findings. SCE’s and SDG&E’s joint 2012 load impact study35

concluded that load increased on Flex Alert days and that there is no evidence that SDG&E’s customers responded any differently on the two joint Peak-Time-Rebate (PTR) and Flex Alert days than they did on the other PTR-only event days.

E. Flex Alert Program Cost/Benefit Overview

The table below outlines the total annual authorized budget, paid media expenditures, fixed administrative costs, agency costs, the number of Flex Alert events, and load impact (if available) per program year since 2006. The Flex Alert program budget from 2006 to 2013 totals $62 million, with 35 events called during this time frame and no conclusive load impacts.

ProgramYear

Annual AuthorizedBudget (total


Paid Media Costs (total

media spend for all IOUs

combined)

Fixed Admin Costs (website, outreach/network,

production)

Agency Costs (media


Number of Flex Alert

Events37

LoadImpact


MWs)38

2006 $ 6,649,247

Data not provided39

18 45 - 75 2007 $ 6,650,076 6 2008 $ 6,650,896 3 222 - 282 2009 $ 5,477,273 0 n/a2010 $ 4,200,292 0 n/a2011 $ 2,929,311 $2,584,945 $ 97,000 $ 311,004 2 n/a2012 $10,000,000 $7,788,166 $715,216 $1,024,633 2 n/a2013 $10,000,000 $8,452,607 $133,000 $1,014,313 3 0 2014 $10,000,000 n/a n/a n/a 1 0

TOTAL $62,557,095 n/a n/a n/a 35 n/a

35 Summary of Evidence of Flex Alert Load Impacts from PY 2012 Evaluations of SCE’s and PG&E’s Peak Time Rebate Programs 36 Authorized Budgets 2006-2008: D.06-03-024, OP 1. Authorized Budgets 2009-2011: D.09-08-027, OP 17. Authorized Budget 2012: D.12-04-045, OP 19. Authorized Budgets 2013-2014: D.13-04-021, OP 1, OP 2, OP 3. 37 Source: http://www.caiso.com/Documents/Alert_WarningandEmergenciesRecord.pdf38 2006-2007 load impact results revised results shown in table as identified in the 2008 Flex Alert Campaign Evaluation Report. 2008 results based on self-reported air-conditioner and lighting behaviors, not verified. 2013 impact study found no statistically significant load reductions attributable to Flex Alert event days. 39 PG&E statewide lead for the Flex Alert program in 2006-2010.

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F. Flex Alert Program Transfer Proposal and Recommendations

1. CAISO Is Willing To Administer the Flex Alert Program

CAISO has the scope of knowledge relative to balancing area resources ability to evaluate and balance resources within its authority area and can initiate a Flex Alert specifically for that area. The CAISO has generation load balancing control over both investor-owned and several municipal electric utilities for the CAISO balancing area, and the Utilities in that area have limited control over the program. However, the CAISO balancing area does not cover all of California. Substantial portions are controlled by other load serving entities and the intent for a statewide program would not be satisfied by a CAISO-only program. Other balancing areas in California have similar knowledge authority for their respective areas, but they do not currently participate in the Flex Alert program (although they may benefit from spillover Flex Alert messaging). A The Commission found that a statewide program was cited asis desirable.40 Nonetheless, CAISO has expressed willingness and is an appropriate entity to administer the Flex Alert program, contingent on the CAISO’s ability to use the Flex Alert brand, and the understanding that the program would be triggered in response to needs of the CAISO balancing area only.

CAISO has expressed its willingness to continue conducting the Flex Alert program functions it currently executes. It has also expressed a willingness to undertake additional responsibilities associated with the Flex Alert program providing that its administration of any Flex Alert functions would only be applicable to CAISO’s balancing area.

However, CAISO has expressed concern over the lack of a funding mechanism proposal for CAISO to cover administrative costs associated with undertaking additional responsibilities whichthat would be transferred to CAISO, including the transfer of the Flex Alert trademark, managing the Flex Alert Network, and additional coordination of websites maintaining the Flex Alert content.

2. Utilities’ Recommendations

Utility funding and administration of the Flex Alert program will not be necessary ifThe Utilities make the following recommendations were implemented:

The Commission should discontinue and eliminate Utility funding for paid media for the Flex Alert program. Research found shows that unpaid media has effectively generated consumer engagement through public

40 D.12-05-015, p.288-299

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service announcements or news media reports.41 Unpaid media is seen as the most compelling and reliable source of information when a Flex Alert event is called. The value of paid media has been disputed by several stakeholders and has not provided quantifiable load impacts. Eliminating the paid statewide campaign is a reasonable approach;.

CAISO should request that Walter McGuire & Company to transfer the Flex Alert trademark and the Flex Alert Network to CAISO. CAISO should manage the Flex Alert Network, which supports the overall communication strategy, as almost all organizations that participated in the Flex Alert Email Survey42 reported that an event causes them to take action;.

CAISO should request that Walter McGuire & Company to transfer the FlexAlert.org URL, redirect traffic to CAISO’s website and discontinue the current Flex Alert website; .

CAISO should include dedicated Flex Alert web content as part of the CAISO website www.caiso.com;.

CAISO should continue its non-unpaid Flex Alert activities, such as CAISO notifications to subscribers via the CAISO website or its smart phone application, Twitter, Google+ and Facebook social media as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.”. In addition, CAISO should coordinate with state agencies to include the Flex Alert logo on government websites. The Flex Alert logo should be switched from green to red during a Flex Alert event;.

The Utilities should can includeintegrate Flex Alert messaging as part of their local demand response ME&O activities. With the discontinuance of paid media for statewide Flex Alert activities discontinued, the Utilities willcan integrate Flex Alert messaging into their local demand response ME&O activities to maintain awareness of the program and support CAISO’s unpaid activities. Examples include SCE’s Summer Readiness residential brochure which includes an explanation of the difference between Save Power Day and Flex Alert, and SCE’s Summer Readiness non-residential flyer with energy saving tips and Flex Alert educational messaging. In addition, the Utilities’ Corporate Communication organizations will can facilitate media coverage when a Flex Alert is issued. This integration significantly reduces, along with awareness efforstefforts by the Statewide ME&O campaign, helps eliminate the need for the ratepayer funding needed and creates an effective alternativeopportunity to continue providing awareness of explain the differences between Flex Alert.s and local demand response notifications. Integrating Flex Alert messaging with Utility-managed demand response general

41 2013 Process Evaluation of the 2013 Statewide Flex Alert Program. February 6, 2014 Flex Alert Media Report 42 2013 Process Evaluation of the 2013 Statewide Flex Alert Program

13

awareness activities can also be supported by the statewide demand response ME&O budgets, which were approved in D.13-12-038.; and

Statewide ME&O should support generating awareness on of Flex Alert.The goal of the Statewide Marketing, Education and Outreach Campaign (Energy Upgrade California), managed by the California Center for Sustainable Energy (CCSE) for the 2014-2015 program cycle, is that “Californians understand the value of energy efficiency, demand response, and distributed generation which leads to demand for products, services and rates for their homes and businesses.” Since generating awareness and understanding of demand response is part of the scope for this campaign, tactics such as paid media, earned/social media, website content, CBO outreach/education, and event outreach include general education about demand response and Flex Alerts. CCSE has also expressed their its support for promoting Flex Alert event days in the “hero box” on the statewide Energy Upgrade California website and via social media channels.

Implementation of these recommendations would transfer and streamline FlexAlert responsibilities and activities to the appropriate organizations. pertaining to the Flex Alert program. The Utilities believe that these recommendations can be implemented before the end of 2014 so that program changes can be executed in 2015.


The Utilities will continue with local demand response program notifications to engage participation and achieve load reductions. In addition, given sufficient advance notice, the Utilities could dispatch certain programs and change website content when a Flex Alert is issued.

G. Exploration of Alternative Entities

The Utilities considered the California Energy Commission (CEC) as an alternative entity to administer and fund the Flex Alert program in preparing this transfer proposal. However, after a preliminary review, the Utilities concluded that a transfer to the CEC would mean exploringrequire an unknown and potentially complex funding structure that may take a lengthy time to construct, adding an additional entity that would need to coordinate with CAISO (the only entity that can initiate a Flex Alert in its balancing area), and determining whether CEC is willing or able to take over the responsibilities for this statewide program. Because CAISO expressed support for accepting administration of the Flex Alert program and they wereit was the only party who recommended exploring additional entities, the Utilities did not engage in discussions with the CEC.

A second alternative entity considered was the California Utilities Emergency Association (CUEA). CUEA serves as a point-of-contact for critical infrastructure

14

utilities and the California Office of Emergency Services (Cal OES) and other Governmental Agencies before, during and after an event to:43




CUEA was recently brought to the Utilities’ attention as an option for taking on the statewide responsibility for the Flex Alert program and was approached in the final stage of preparing this transfer proposal. Due to the limited opportunity for CUEA to provide input, the Utilities have not received their its feedback and it is not incorporated herein. .

H. Flex Alert Brand

The Flex Alert brand is owned by Walter McGuire & Company, Inc. (McGuire) as of November 9, 2010.44 Continuing with this brand name, therefore, would require requires approval from McGuire as neither CAISO nor the Commission owns the trademark.

Research has shownindicates45 that inconsistent and infrequently changing program names and logos are confusing and weaken the message. The Utilities recommended that CAISO explore obtaining the required approvals to continue with the Flex Alert brand.

SCE facilitated a meeting on March 17, 2014, between CAISO and McGuire in which the following topics were covered regarding the Flex Alert brand:



43 Source: www.cueainc.com 44 United States Patent and Trademark Office: Registration Number 3872849 45 2006-2007 Flex Your Power NOW! Evaluation Report

15





CAISO and McGuire agreed that a contract would be required if this activity is to continue in its current form in 2015.


each member by phone to ensure accuracy of contact information. Network members are alerted through e-blasts distributed by McGuire.

Transferring the e-blast responsibilities to another entity, such as the CAISO, would require a review of the agreements McGuire holds with the Network members to determine if this would be allowed.

I. Conclusion

The Utilities recommend that the Commission eliminates Utility funding for paid media for the Flex Alert program and forthat CAISO to continue its non-unpaid Flex Alert activities as described in the “Flex Alert Messaging Coordination and Optimization Report for Summer 2013.”. In addition, the Utilities recommend forthat CAISO totakeobtain ownership of the Flex Alert brand and the FlexAlert.org URL.

The Utilities can integrate Flex Alert messaging as part of their local ME&O activities with statewide ME&O supporting generating awareness of Flex Alert.

CAISO has expressed its willingness to continue conducting the Flex Alert program functions it currently executes and undertake additional responsibilities for theirits balancing area only. However, CAISO is concerned over the lack of a funding mechanism proposal to cover administrative costs associated with undertaking these additional responsibilities, which would include the transfer of the Flex Alert trademark, managing the Flex Alert Network, and coordination of websites maintaining the Flex Alert content.

Implementation of the recommendations proposed by the Utilities would streamline Flex Alert responsibilities and activities to the appropriate organization. The

16

Utilities believe that these recommendations can be implemented before the end of 2014 so that program changes can be executed in 2015.

The Utilities are supportive of CAISO continuing the Flex Alert program and undertaking the additional responsibilities outlined above but recommend for CAISO to find a funding solution for the administrative costs associated with these activities.

17

APPENDIX A




Exhibit 5

1

Andrea Tozer

From: Roland Mollen <[email protected]>Sent: Friday, July 31, 2015 11:22 AMTo: Andrea TozerCc: David Lowrey; Roland MollenSubject: Fw: Final review: Flex Alert Transfer Proposal

Confirmation from ISO



From: "Van Pelt, Gregory" <[email protected]>To: "'[email protected]'" <[email protected]>, "McKenna, Anna" <[email protected]>, "Yip, Andrew" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "Long, Lisa" <[email protected]>, "Agustin, Melody" <[email protected]>, "[email protected]" <[email protected]>, Cc: "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>, "[email protected]" <[email protected]>Date: 04/01/2014 10:30 AMSubject: RE: Final review: Flex Alert Transfer Proposal

Roland,

The ISO is okay with this version. We may file comments when the ALJ issues a proposed decision.

Regards,

Gregory Van Pelt

Office: 916-351-2190 Cell: 916-802-9133

2


If you have received this electronic message in error, please notify the sender immediately. The foregoing e mail communication (together with any attachments thereto) isintended for the designated recipient(s) only. Its terms are confidential and may be protected by the attorney/client, or other applicable, privilege. If you are not the intendedrecipient, you are hereby notified that any use, disclosure, copying, distribution (electronic or otherwise), or taking any action in reliance on the contents of this information isstrictly prohibited.

From: [email protected] [mailto:[email protected]]Sent: Monday, March 31, 2014 8:37 PMTo: McKenna, Anna; Yip, Andrew; [email protected]; Van Pelt, Gregory; [email protected]; Long, Lisa; Agustin, Melody; [email protected]: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]: Final review: Flex Alert Transfer Proposal

< EXTERNAL email. Evaluate before clicking. >

All,

The Commission was closed today due to the Cesar Chavez holiday and this provided us with some extra time to incorporate all the edits we've received from the stakeholders to this proposal. Attached you'll find the final draft, with edits in tracked changes. Kind request to take one last look and send me your final thoughts and/or approval by 11:00 tomorrow. We'll file the report in the afternoon.

Many thanks to all of you for your contributions!



EMAIL DISCLAIMERPlease Note: The information contained in this message may be privileged and confidential, protected from disclosure, and/or intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, distribution, copying or other dissemination of this communication is strictly prohibited. If you

received this communication in error, please immediately reply to the sender, delete the message and destroy all copies of it.

3

From: Roland Mollen/SCE/EIXTo: "Yip, Andrew" <[email protected]>, "Long, Lisa" <[email protected]>, "Agustin, Melody" <[email protected]>, [email protected],[email protected], [email protected], "McKenna, Anna" <[email protected]>, "Van Pelt, Gregory" <[email protected]>,

Cc: Andrea Tozer/SCE/EIX@SCE, David Lowrey/SCE/EIX@SCE, Aimee Wong/SCE/EIX@SCE, Michelle Thomas/SCE/EIX, Brian Kopec/SCE/EIX@SCE

Date: 03/28/2014 04:51 PM

Subject: Final review: Flex Alert Transfer Proposal


All,



[attachment "Flex Alert Transfer Proposal - V12.docx" deleted by Roland Mollen/SCE/EIX]




EMAIL DISCLAIMERPlease Note: The information contained in this message may be privileged and confidential, protected from disclosure, and/or intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, distribution, copying or other dissemination of this communication is strictly prohibited. If you

received this communication in error, please immediately reply to the sender, delete the message and destroy all copies of it.

*********************************************************************************************The foregoing electronic message, together with any attachments thereto, is confidential and may be legally privileged against disclosure other than to the intended recipient. It is intended solely for the addressee(s) and access to the message by anyone else is unauthorized. If you are not the intended recipient of this electronic

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message, you are hereby notified that any dissemination, distribution, or any action taken or omitted to be taken in reliance on it is strictly prohibited and may be unlawful. If you have received this electronic message in error, please delete and immediately notify the sender of this error. *********************************************************************************************

1


STATE OF CALIFORNIA




Application 12-08-008 Application 12-08-009 Application 12-08-010

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY’S (U 338-E) RESPONSE TO ADMINISTRATIVE LAW JUDGE ROSCOW’S ORAL REQUEST AT THE PREHEARING CONFERENCE on all parties identified on the attached service list A.12-08-007 et al. Service was effected by one or more means indicated below:

☒ Transmitting the copies via e-mail to all parties who have provided an e-mail address.

☒ Placing the copies in sealed envelopes and causing such envelopes to be delivered by hand or by overnight courier to the offices of the Assigned ALJ(s) or other addressee(s).

ALJ Stephen C. Roscow CPUC 505 Van Ness Ave. San Francisco, CA 94102

☒ Placing copies in properly addressed sealed envelopes and depositing such copies in the United States mail with first-class postage prepaid to all parties for those listed on the attached non-email list.

☐ Directing Prographics to place the copies in properly addressed sealed envelopes and to deposit such envelopes in the United States mail with first-class postage prepaid to all parties.

Executed July 31, 2015, at Rosemead, California.

2

/S/ Irene Gutierrez Irene Gutierrez Legal Assistant SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

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HOWARD CHOY JEREMY WAEN G.M., OFFICE OF SUSTAINABILITY SR. REGULATORY ANALYST COUNTY OF LOS ANGELES MARIN CLEAN ENERGY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE SOUTHERN CALIFORNIA REGIONAL FOR: MARIN CLEAN ENERGY ENERGY NETWORK STEVEN D. PATRICK CHAIRMAN / PRESIDENT ATTORNEY LAT. BUS. CHAMBER OF GREATER L.A. SDG&E / SOCAL GAS 634 S. SPRING STREET, STE 600 555 WEST FIFTH STREET, GT14E7 LOS ANGELES, CA 90014 LOS ANGELES, CA 90013-1011 FOR: LATINO BUSINESS CHAMBER OF GREATER FOR: SAN DIEGO GAS & ELECTRIC (SDG&E) LOS ANGELES AND SOUTHERN CALIFORNIA GAS (SOCALGAS) ANDREA L. TOZER SACHU CONSTANTINE ATTORNEY DIRECTOR OF POLICY SOUTHERN CALIFORNIA EDISON COMPANY CENTER FOR SUSTAINABLE ENERGY 2244 WALNUT GROVE AVE. / PO BOX 800 8690 BALBOA AVE., STE. 100 ROSEMEAD, CA 91770 SAN DIEGO, CA 92123 FOR: SOUTHERN CALIFORNIA EDISON COMPANY FOR: CALIFORNIA CENTER FOR SUSTAINABLE ENERGY THOMAS R. BRILL FAITH BAUTISTA SR COUNSEL & DIRECTOR PRESIDENT & CEO SAN DIEGO GAS & ELECTRIC COMPANY NATIONAL ASIAN AMERICAN COALITION 8330 CENTURTY PARK CT., CP32E 15 SOUTHGATE AVE., STE. 200 SAN DIEGO, CA 92123-1530 DALY CITY, CA 94015 FOR: SAN DIEGO GAS & ELECTRIC COMPANY FOR: NATIONAL ASIAN AMERICAN COALITION CANDACE CHOE BILL NUSBAUM CALIF PUBLIC UTILITIES COMMISSION MANAGING ATTY LEGAL DIVISION THE UTILITY REFORM NETWORK AREA 3-F 785 MARKET ST., STE. 1400 505 VAN NESS AVENUE SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94102-3214 FOR: THE UTILITY REFORM NETWORK FOR: ORA SHIRLEY A. WOO GERALD LAHR

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ATTORNEY AT LAW ENERGY PROGRAMS MGR. PACIFIC GAS AND ELECTRIC COMPANY ASSOCIATION OF BAY AREA GOVERNMENTS PO BOX 7442, MC B30A 101 8TH ST. SAN FRANCISCO, CA 94120-7442 OAKLAND, CA 94607 FOR: PACIFIC GAS & ELECTRIC COMPANY FOR: THE SAN FRANCISCO BAY AREA REGIONAL ENERGY NETWORK (BAYREN) LEN CANTY MELISSA KASNITZ CHAIRMAN ATTORNEY BLACK ECONOMIC COUNCIL CENTER FOR ACCESSIBLE TECHNOLOGY 484 LAKE PARK AVE., SUITE 338 3075 ADELINE STREET, STE. 220 OAKLAND, CA 94610 BERKELEY, CA 94703 FOR: BLACK ECONOMIC COUNCIL FOR: CENTER FOR ACCESSIBLE TECHNOLOGY CARMELITA L. MILLER COLIN CLARK LEGAL COUNSEL PROGRAM DEVELOPMENT MGR. THE GREENLINING INSTITUTE ECOLOGY ACTION OF SANTA CRUZ, INC. 1918 UNIVERSITY AVENUE 877 CEDAR STREET, STE. 240 BERKELEY, CA 94704 SANTA CRUZ, CA 95060 FOR: THEH GREENLINING INSTITUTE FOR: ECOLOGY ACTION OF SANTA CRUZ, INC. JORDAN PINJUV MARCO LIZARRAGA COUNSEL LA COOPERATIVA CAMPESINA DE CALIFORNIA CALIFORNIA ISO 1107 9TH STREET, STE. 420 250 OUTCROPPING WAY SACRAMENTO, CA 95814 FOLSOM, CA 95630 FOR: LA COOPERATIVA CAMPESINA DE FOR: CALIFORNIA INDEPEDENT SYSTEM CALIFORNIA OPERATOR (CAISO)

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ANDREW YIP CASE COORDINATION PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CASSANDRA FELICIANO CASSANDRA YAMASAKI REGULATORY CASE MANAGER NATIONAL ASIAN AMERICAN COALITION PACIFIC GAS AND ELECTRIC COMPANY EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 CHUCK BUCK HANNA GRENE MANAGER, REGULATORY AFFAIRS CENTER FOR SUSTAINBLE ENERGY OPOWER EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 HUGH YAO JESSICA COHEN SOUTHERN CALIFORNIA GAS COMPANY MANAGEMENT FOLLOW/PROGRAM MANAGER EMAIL ONLY L.A.COUNTY OFFICE OF SUSTAINABILITY EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 JESSICA TAM JODY S. LONDON SPECIAL COUNSEL JODY LONDON CONSULTING NATIONAL ASIAN AMERICAN COALITION EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: LOCAL GOVERNMENT SUSTAINABLE ENERGY COALITION LARA ETTENSON LAURA BRENNER KIMES NATURAL RESOURCES DEFENSE COUNCIL LAURA BRENNER KIMES, LLC EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, IL 00000 MCE REGULATORY MIKE CADE MARIN CLEAN ENERGY ALCANTAR & KAHL, LLP EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, OR 00000 SEPHRA A. NINOW, J.D. SHALINI SWAROOP REGULATORY AFFAIRS MGR. REGULATORY COUNSEL CENTER FOR SUSTAINABLE ENERGY MARIN CLEAN ENERGY

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EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 TADASHI GONDAI MRW & ASSOCIATES, LLC STAFF ATTORNEY EMAIL ONLY NATIONAL ASIAN AMERICAN COALTION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 ANDREW STEINBERG DEANA NG REGULATORY POLICY & REPORTING MGR. SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. FIFTH STREET, GT19A7 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 ELIZABETH BAIRES JEFF SALAZAR REGULATORY MGR SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA GAS COMPANY 555 W. FIFTH STREET, GT14D6 555 W. FIFTH ST., GT14D6 LOS ANGELES, CA 90013 LOS ANGELES, CA 90013 STEVE HRUBY CASE ADMINISTRATION SOUTHERN CALIFORNIA GAS COMPANY SOUTHERN CALIFORNIA EDISON COMPANY 555 W. FIFTH ST., GT22P4 LAW DEPT. LOS ANGELES, CA 90013 2244 WALNUT GROVE AVE., RM 370 ROSEMEAD, CA 91770 DAVID LEBLOND DAVID P. LOWREY SOUTHERN CALIFORNIA EDISON COMPANY REGULATORY POLICY & AFFAIRS 2244 WALNUT GROVE AVE. SOUTHERN CALIFORNIA EDISON COMPANY ROSEMEAD, CA 91770 8631 RUSH STREET ROSEMEAD, CA 91770 DON C. LIDDELL ANNLYN M. FAUSTINO ATTORNEY REGULATORY CASE ANALYST & SUPPORT DOUGLASS & LIDDELL SDG&E/SCGC 2928 2ND AVENUE 8330 CENTURY PARK COURT, CP31E SAN DIEGO, CA 92103 SAN DIEGO, CA 92123 CENTRAL FILES JOY C. YAMAGATA SDG&E/SOCALGAS REGULATORY MANAGER 8330 CENTURY PARK COURT, CP31-E SAN DIEGO GAS & ELECTRIC / SOCALGAS SAN DIEGO, CA 92123 8330 CENTURY PARK COURT, CP 31 D SAN DIEGO, CA 92123-1530 ATHENA BESA PAUL KERKORIAN CUSTOMER PROGAMS & POLICY MANAGER ATTORNEY AT LAW SAN DIEGO GAS & ELECTRIC COMPANY 6475 N PALM AVE., STE. 105 8335 CENTURY PARK COURT, CP12H FRESNO, CA 93704 SAN DIEGO, CA 92123-1569 AARON J. LEWIS ROBERT GNAIZDA COUNSEL OF COUNSEL NATIONAL ASIAN AMERICAN COALITION 15 SOUTHGATE AVE., STE. 200 15 SOUTHGATE AVE., STE. 200 DALY CITY, CA 94015 DALY CITY, CA 94015 STEPHEN STOLTE RORY COX COORDINATOR - OFFICE OF SUSTAINABILITY CALIF PUBLIC UTILITIES COMMISSION COUNTY OF SAN MATEO ENERGY EFFICIENCY BRANCH 400 COUNTY CENTER AREA 4-A REDWOOD CITY, CA 94063 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 ELISE TORRES MARCEL HAWIGER STAFF ATTORNEY STAFF ATTORNEY THE UTILITY REFORM NETWORK THE UTILITY REFORM NETWORK 785 MARKET STREET, SUITE 1400 785 MARKET ST., STE. 1400 SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94103 JENNY GLUZGOLD JOSEPHINE WU CASE MANAGER PACIFIC GAS & ELECTRIC COMPANY PACIFIC GAS & ELECTRIC COMPANY 77 BEALE STREET, ROOM 975 77 BEALE ST./PO BOX 7442/ MC B9A SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 MARDI WALTON HILLARY CORRIGAN

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SR. REGULATORY ANALYST CALIFORNIA ENERGY MARKETS PACIFIC GAS AND ELECTRIC COMPANY 425 DIVISADERO ST. STE 303 77 BEALE STREET, MC B10B, RM 1003 SAN FRANCISCO, CA 94117-2242 SAN FRANCISCO, CA 94105 STEVE R. HAERTLE JENNIFER K. BERG CASE MANAGER - ENERGY PROCEEDINGS BAYREN PROGRAM MANAGER PACIFIC GAS & ELECTRIC COMPANY ASSOCIATION OF BAY AREA GOVERNMENTS PO BOX 7442, MC-B9A 101 - 8TH STREET SAN FRANCISCO, CA 94120 OAKLAND, CA 94607 MIKHAIL HARAMATI STEPHANIE WANG ASSOCIATE SR. POLICY ATTORNEY OPINION DYNAMICS CORPORATION CENTER FOR SUSTAINABLE ENERGY 1999 HARRISON ST., STE. 1420 426 17TH STREEET, SUITE 700 OAKLAND, CA 94612 OAKLAND, CA 94612 STEPHANIE C. CHEN VIEN TROUNG DIR - ENERGY / TELECOMM POLICY ENVIRONMENTAL EQUITY DIRECTOR THE GREENLINING INSTITUTE THE GREENLINING INSTITUTE 1918 UNIVERSITY AVE., 2ND FL. 1918 UNIVERSITY AVENUE, 2ND FLOOR BERKELEY, CA 94704 BERKELEY, CA 94704 NATALIE DE LEON DENNIS PETERS COUNTY OF SANTA CLARA CALIFORNIA ISO 70 W. HEDDING 250 OUTCROPPING WAY SAN JOSE, CA 95110 FOLSOM, CA 95630 LEGAL DEPARTMENT ROBERT CASTANEDA CALIFORNIA ISO LA COOPERATIVA CAMPESINA DE CALIFORNIA 250 OUTCROPPING WAY 1107 9TH ST., STE. 420 FOLSOM, CA 95630 SACRAMENTO, CA 95814

State Service

DAVID PECK DORRIS CHOW CALIFORNIA PUBLIC UTILITIES COMMISSION REGULATORY ANALYST - ENERGY DIV. EMAIL ONLY CALIFORNIA PUBLIC UTILITIES COMMISSION EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 MICHAEL COLVIN ANDREW KOTCH ADVISOR CALIF PUBLIC UTILITIES COMMISSION CPUC - ENERGY EXECUTIVE DIVISION EMAIL ONLY ROOM 5301 EMAIL ONLY, CA 00000 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 JACLYN MARKS JOANNA GUBMAN CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ENERGY EFFICIENCY BRANCH ENERGY EFFICIENCY BRANCH AREA 4-A AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 STEPHEN C. ROSCOW XIAN "CINDY" LI CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION DIVISION OF ADMINISTRATIVE LAW JUDGES ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 5010 ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

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NON EMAIL SERVICE LIST

Len Canty, Chairman” Black Economic Council 484 Lake Park Avenue, Suite 338 Oakland, CA 94610